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Petitioner was a holding company. Before June 21, 1993,
petitioner held over 80 percent of the stock of five C
corporations, namely, Coggin Pontiac, Inc., Coggin Nissan, Inc.,
Coggin-O’Steen Imports, Inc., Coggin-O’Steen Motors, Inc., and
Coggin Imports, Inc. (collectively, the subsidiaries), all of which
were engaged in the retail sales of automobiles and light trucks.
Each subsidiary was incorporated in Florida.
Six automobile dealerships were operated through the
subsidiaries (five through direct ownership and one through
ownership of a 50-percent general partnership interest). Four of
the dealerships (Coggin Pontiac-GMC, Coggin Honda, Coggin Nissan,
and Coggin Acura) were located in Jacksonville, Florida; one
(Coggin Motor Mall) was located in Fort Pierce, Florida; and one
(Coggin-Andrews Honda) was located in Orlando, Florida.
From 1972 or 1973 until and including the fiscal year ended
June 26, 1993, petitioner (as the common parent) filed consolidated
Forms 1120, U.S. Corporation Income Tax Return, with its
subsidiaries (hereinafter, the affiliated group).1 The
subsidiaries maintained their inventories of automobiles and light
trucks under the dollar-value LIFO method of accounting.
1 Petitioner and its subsidiaries reported their
consolidated income on a 52- to 53-week basis; the fiscal year of
the affiliated group ended in June.
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