115 T.C. No. 28
UNITED STATES TAX COURT
COGGIN AUTOMOTIVE CORPORATION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1684-99. Filed October 18, 2000.
P was a holding company that held over 80 percent of
the stock of five corporations (collectively, the
subsidiaries) that were engaged in the retail sales of
automobiles and light trucks conducted through six
dealerships. From 1972 or 1973 until and including the
fiscal year ended June 26, 1993, P (as common parent)
filed consolidated corporate income tax returns with its
subsidiaries. The subsidiaries maintained their
inventories of automobiles and light trucks under the
dollar-value LIFO method of accounting. P did not
directly own any inventory.
From Jan. 29, 1970 (the date of incorporation),
until June 27, 1993, P was a C corporation. On or about
Aug. 27, 1993, P elected S corporation status, effective
June 27, 1993. The election was made pursuant to a
restructuring plan. The restructuring resulted in the
establishment of six new S corporations formed for the
purpose of becoming general partners in six limited
partnerships that would operate the six dealerships.
Each subsidiary contributed the assets and liabilities of
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011