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Unless otherwise stated, all section references are to the
Internal Revenue Code in effect for 1997, the year at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Background
Introduction
This case was submitted for decision without trial pursuant
to Rule 122. Facts stipulated by the parties are so found. The
stipulation of facts filed by the parties, with attached
exhibits, is included herein by this reference. Respondent
objects, on the grounds of relevance, to 26 exhibits referenced
in certain of the stipulations. See the discussion infra section
IV.
Petitioner is a Delaware corporation, whose shares are
publicly traded and which maintains its principal place of
business in New York, New York.
Business Activities of the Affiliated Group
Together, the affiliated group is a diversified industrial
manufacturer, producing through its members and foreign
subsidiaries a broad range of products and sophisticated
manufacturing equipment for other industries and businesses.
During and prior to 1997, the group’s business activities were
divided into five business groups, one of which was known as
Dover Elevator.
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