- 3 - stock were worthless in the taxable years the disputed deductions were claimed.3 Respondent concedes, however, that all of the disallowed worthless stock and bad debt deductions constitute a long-term capital loss for FYE May 31, 1994. FINDINGS OF FACT Some of the facts, and pertinent German law, have been stipulated for purposes of these proceedings and are so found or stated. The stipulations are incorporated herein by this reference. I. In General At the time the petition was filed, Flint Industries, Inc. (Flint), was a corporation with its principal place of business in Tulsa, Oklahoma. For all relevant years, Flint was the common parent of a group of affiliated corporations that filed a consolidated corporate income tax return for each of the taxable years at issue.4 For all relevant years, Flint used the accrual method of accounting and a fiscal year ended May 31. 3As a result of respondent’s determination that petitioner was not entitled to the claimed bad debt deductions, respondent made a corollary adjustment to petitioner’s interest income. Respondent agrees that this adjustment will be resolved consistent with our resolution of the bad debt issue. Petitioner also alleges error in the computation of the deficiencies. The parties agree that the computational matters will be addressed in the Rule 155 computation. 4In its reply brief, petitioner states that only Flint and its domestic subsidiaries filed consolidated returns for the years at issue; G�nther, a foreign subsidiary, was not eligible to be included, and was not included, in the consolidated group.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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