MMC Corp., Midwest Mechanical Contractors, Inc., M W Builders, Inc., Midwest Mehanical Contractors of New Jersey, Inc., and Pahor Air Conditioning, Inc. - Page 2




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          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.                                                        





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