Coggin Automotive Corporation - Page 4




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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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