- 3 -
stipulated facts and certain stipulated exhibits. Our findings
of fact in this case are set forth in full in Intermet Corp. &
Subs. v. Commissioner, 111 T.C. 294 (1998), revd. and remanded
209 F.3d 901 (6th Cir. 2000). For convenience, we only restate
the findings of fact that are material to the issue presented.
Petitioner is the common parent of an affiliated group of
corporations that manufacture precision iron castings for
automotive and industrial equipment producers. Petitioner filed
consolidated Federal income tax returns for calendar years 1984
through 1993. During those years, petitioner’s members used the
accrual method of accounting for both financial accounting and
Federal income tax purposes. During the years 1984 through 1993,
Lynchburg Foundry Co. (Lynchburg) was a member of the
consolidated group.
Petitioner reported a consolidated net operating loss (CNOL)
in the amount of $25,701,038 on its 1992 Federal income tax
return. In October 1994, petitioner filed Form 1120X, Amended
U.S. Corporation Income Tax Return, for 1992, claiming a
carryback of $1,227,973 to 1984 for specified liability losses
incurred by its members. During 1992, petitioner’s CNOL exceeded
the sum of its claimed specified liability losses.
Respondent issued a notice of deficiency to petitioner
determining a deficiency of $615,019 in its consolidated Federal
income tax return for 1984 based upon the disallowance of a
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011