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See id. Section 1.6012-2(g)(1), Income Tax Regs., generally
requires that a foreign corporation file a Federal income tax
return on Form 1120-F if it “is engaged in trade or business in
the United States at any time during the taxable year or * * *
has income which is subject to taxation under subtitle A of the
Code (relating to income taxes)”.
Section 6072 sets the time for the filing of Federal income
tax returns required by section 6012. A corporation generally
must file its return by the 15th day of the third month following
the close of its taxable year. See sec. 6072(b); see also sec.
1.6072-2(a), Income Tax Regs. An exception to this rule is found
in the case of a foreign corporation without an office or place
of business in the United States. In such a case, the foreign
corporation may file its tax return up until the 15th day of the
sixth month following the close of its taxable year. See sec.
6072(c); see also sec. 1.6072-2(b), Income Tax Regs.
Petitioner did not conduct a trade or business in the United
States at any time from its inception through the close of the
last subject year. Thus, but for an election under section
882(d)(1), petitioner was required by section 6012(a), as
interpreted by section 1.6012-2(a)(1) and (g)(1), Income Tax
Regs., to file a Federal income tax return for a taxable year
included within that period only if it had income subject to
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