- 2 - Debra Sadow Koenig, for petitioner. Lawrence C. Letkewicz, Christa A. Gruber, and Sharon S. Galm, for respondent. OPINION LARO, Judge: This case was submitted to the Court under Rule 122 for decision without trial.1 Petitioner petitioned the Court to redetermine respondent’s determination of deficiencies of $33,622, $38,571, $41,654, and $31,868 in the 1999, 2000, 2001, and 2002 Federal income taxes, respectively, of its affiliated group. For those years, the group filed consolidated Federal corporate income tax returns. The group included petitioner, petitioner’s wholly owned subsidiary Peoples State Bank (Peoples), and Peoples’ wholly owned investment subsidiary PSB Investments, Inc. (Investments). We decide whether Peoples must include the tax-exempt obligations purchased and owned by Investments in the calculation of Peoples’ average adjusted bases of tax-exempt obligations under sections 265(b)(2)(A) and 291(e)(1)(B)(ii)(I). We hold that the calculation does not include those obligations. 1 Rule references are to the Tax Court Rules of Practice and Procedure. Unless otherwise noted, section references are to the applicable versions of the Internal Revenue Code.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008