- 2 - Year Deficiency 1981 $ 12,593,692 1982 51,639,634 1983 82,327,873 1984 153,418,047 1985 223,328,166 After concessions, the issue for decision is whether petitioner sold property to its wholly owned subsidiary in intercompany transactions pursuant to section 1.1502-13, Income Tax Regs., where the subsidiary received its rights to acquire the property by assignment from third parties who were not members of petitioner’s consolidated group. This issue is before the Court on cross-motions for partial summary judgment pursuant to Rule 121. The record shows, and the parties agree, that there is no genuine issue of material fact. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Background Northern Telecom Inc. (petitioner) is the common parent of an affiliated group of corporations, which, at the time of the filing of the petition, had a principal place of business in Nashville, Tennessee. Petitioner is a corporation organized and existing under the laws of the State of Delaware. Petitioner and its subsidiaries filed consolidated Federal income tax returns during all of the years in issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011