Coggin Automotive Corporation - Page 1

                                   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