- 2 -
concessions,1 we must determine whether petitioners are required
to include section 481 adjustments as recognized built-in gain
for 2000 and 2001 (the years at issue).2 We hold that they are.
Background
This case was submitted fully stipulated pursuant to Rule
122, and the facts are so found. The stipulation of facts, the
supplemental stipulation of facts, and the accompanying exhibits
are incorporated by this reference. Petitioners’ principal place
of business was Overland Park, Kansas, at the time they filed the
petition.
The Corporations and the Corporate Structure
The corporations involved in this litigation are in the
construction services business. MMC Corp. (MMC) was incorporated
under Kansas law in 1960. MMC owns several subsidiaries which
are also petitioners in this case. These subsidiaries include
Pahor Air Conditioning, Inc. (Pahor), a company MMC acquired in
June 2000, as well as Midwest Mechanical Contractors, Inc.
(Midwest), M W Builders, Inc. (MW), and Midwest Mechanical
Contractors of New Jersey, Inc. (Jersey). MMC wholly owned
Midwest, MW, and Jersey, which were all C corporations, from 1997
1The parties have resolved all other issues raised in the
deficiency notice and the petition.
2All section references are to the Internal Revenue Code
(Code) in effect for the years at issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure, unless
otherwise indicated.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: March 27, 2008