-15-
Federal income tax.8 Petitioner had no such income for its first
taxable year but did have such income for each of its taxable
years thereafter through the close of the last subject year. For
each of the subject years, therefore, petitioner was required to
file a Form 1120-F with the Commissioner. Because petitioner was
within the rule of section 6072(c) for each of those years, the
due dates of the subject returns were November 15, 1994, 1995,
and 1996, respectively.
IV. Place for Filing Returns
Section 6091(b)(2) sets forth the rules concerning the place
where a corporation must file its Federal income tax returns.
That section was enacted as part of the Internal Revenue Code of
1954 (1954 Code), ch. 736, 68A Stat. 752, to replace section
53(b)(2) of the Internal Revenue Code of 1939 (1939 Code), ch. 2,
53 Stat. 28. Former section 53(b)(2), which also appeared in the
Revenue Act of 1928, 45 Stat. 808, and the Revenue Act of 1932,
47 Stat. 189, provided:
(2) CORPORATIONS.--Returns of corporations shall
be made to the collector of the district in which is
located the principal place of business or principal
office or agency of the corporation, or, if it has no
principal place of business or principal office or
agency in the United States, then to the collector at
Baltimore, Maryland.
8 Petitioner would have been required by sec. 6012(a), as
interpreted by sec. 1.6012-2(a)(1) and (g)(1), Income Tax Regs.,
to file a return for any taxable year in which it had a sec.
882(d)(1) election in effect. Such an election was in effect as
to petitioner only during the subject years.
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