- 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 NextLast modified: March 27, 2008