§1501 Privilege to file consolidated returns

DIST. Uniband, Inc., Petitioner 140 T.C. No. 13 · 2013

Accordingly, unlike TMBCI, Uniband is subject to Federal income tax. II. Consolidated return issue We now turn to Uniband's alternative claim that for tax years 1996, 1997, and 1998 it was entitled to and did properly file consolidated returns with its sister corporation TMMC. The filing ofa consolidated return is a "privilege", sec. 1501, as to which the Secretary is explicitly authorized to promulgate regulations,25 sec.

DIST. People Place Auto Hand Carwash, LLC, Petitioner 126 T.C. No. 19 · 2006

1501, 119 Stat . 134 . Consequently, this amendment is inapplicable with respect to the bankruptcy cases filed by the Conways .

FOLLOWED Duquesne Light Holdings, Inc. & Subsidiaries f.k.a. DQE, Inc. & Subsidiaries, Petitioners T.C. Memo. 2013-216 · 2013

and in the instant case.19 Section 1501 provides that an affiliated group ofcorporations shall have the privilege offiling a consolidated income tax return.

FOLLOWED Wells Fargo and Company, and Subsidiaries, Successor in Interest to Intrawest Financial Corporation and Subsidiaries; f.k.a. Norwest Corporation and Subsidiaries, Successor in Interest to Intrawest Financial Corporation and Subsidiaries, Petitioners 111 T.C. No. 5 · 1998

Section 1501 provides, in part, as follows: .

Uniband, Inc. v. Commissioner 140 T.C. 230 · 2013

t to the corporate income tax under section 11. We hold that it is subject to tax. (2) Whether, if Uniband is subject to tax, the consolidated returns that Uniband and its sister corporation joined in filing for 1996, 1997, and 1998 were valid under section 1501. We hold that they were not valid. (3) Whether section 280C(a) requires that Uniband’s section 162 deductions for wage and employee expenses be reduced by the entire amount of the Indian employment credit for which Uniband was eligible u

Chevron Corp. v. Commissioner 104 T.C. 719 · 1995

The “group” aspect that they complain of has everything to do with combined reporting and the existence of combined preapportionment income. Indeed, as we understand petitioners “group” method objection, it would apply equally to a domestic corporation with a wholly owned foreign subsidiary, which is ineligible to make a consolidated ret

David Taylor Enterprises, Inc. & Subsidiaries, Petitioner T.C. Memo. 2005-127 · 2005

The common parent of the affiliated group is David Taylor Enterprises, Inc. (DTE). Until his death, David Taylor, Sr. (Mr. Taylor) owned all the shares of DTE. DTE’s principal place of business was Houston, Texas, at the time it filed the petition. David Taylor Cadillac Cars were Mr. Taylor’s love and passion, and he was involved in the

Wells Fargo and Company, and Subsidiaries; Successor in Interest to United Banks of Colorado, Inc., and Subsidiaries, f.k.a. Norwest Corporation and Subsidiaries, Successor in Interest to United Banks of Colorado, Inc., and Subsidiaries, Petitioners 111 T.C. No. 5 · 1998

Section 1501 provides, in part, as follows: - 72 - An affiliated group of corporations shall * * * have the privilege of making a consolidated return with respect to the income tax imposed by chapter 1 for the taxable year in lieu of separate returns. The making of a consolidated return shall be upon the condition that all corporations which at an

Wells Fargo and Company, Successor in Interest to United Banks of Colorado, Inc., and Subsidiaries; f.k.a. Norwest Corporation, Successor in Interest toUnited Banks of Colorado, Inc., and Subsidiaries, Petitioners 111 T.C. No. 5 · 1998

Section 1501 provides, in part, as follows: - 72 - An affiliated group of corporations shall * * * have the privilege of making a consolidated return with respect to the income tax imposed by chapter 1 for the taxable year in lieu of separate returns. The making of a consolidated return shall be upon the condition that all corporations which at an

Lone Star Life Insurance Company, Petitioner T.C. Memo. 1997-465 · 1997

Hibiscus timely filed consolidated Federal income tax returns, Forms 1120L, pursuant to section 1501 for the taxable years 1988, 1989, 1990, and 1991 on September 14, 1989, September 17, 1990, September 16, 1991, and September 14, 1992, respectively.3 During the years in issue, Hibiscus and petitioner shared common corporate officers as well as the same mailing address.

Kolonaki Imports, Inc., Petitioner T.C. Memo. 1995-546 · 1995

Under section 1501, an affiliated group has the privilege of making a consolidated return. An affiliated group is defined in section 1504(a) as follows: (a) Affiliated Group Defined.--For purposes of this subtitle-- (1) In general.--The term "affiliated group" means-- (A) 1 or more chains of includible corporations connected through stock ownership with

Georgiou Retail Stores, Petitioner T.C. Memo. 1995-546 · 1995

Under section 1501, an affiliated group has the privilege of making a consolidated return. An affiliated group is defined in section 1504(a) as follows: (a) Affiliated Group Defined.--For purposes of this subtitle-- (1) In general.--The term "affiliated group" means-- (A) 1 or more chains of includible corporations connected through stock ownership with

George Georgiou & Judith Georgiou, a.k.a. Judy Georgiou, Petitioners T.C. Memo. 1995-546 · 1995

Under section 1501, an affiliated group has the privilege of making a consolidated return. An affiliated group is defined in section 1504(a) as follows: (a) Affiliated Group Defined.--For purposes of this subtitle-- (1) In general.--The term "affiliated group" means-- (A) 1 or more chains of includible corporations connected through stock ownership with

Computer Sciences Corporation, Petitioner 165 T.C. No. 8 · 2025

CSC and its subsidiaries engaged in various aspects of the information technology business. CSC had its principal place of business in Virginia when the Petition was timely filed. Absent stipu- lation to the contrary, this case is appealable to the U.S. Court of Ap- peals for the Fourth Circuit. See § 7482(b)(1)(B). During FY2013 CSC sold i

Growmark, Inc. & Subsidiaries, Petitioner 160 T.C. No. 11 · 2023

109-58, § 1501(a)(2), 119 Stat. 594, 1068, which mandated the inclusion of a minimum volume of renewable fuels in gasoline sold or introduced into commerce in the United States. It mandated that 6.1 and 6.8 billion gallons of renewable fuel be introduced into the nation’s fuel supply during 2009 and 2010, respectively. Id. at 1069. The creation of a renewa

3M Company and Subsidiaries, Petitioner 160 T.C. No. 3 · 2023

An affiliated group that has filed a consolidated return for a year is referred to as a consolidated group. 26 C.F.R. sec. 1.1502-1(h), (a) (2019). A consolidated group has only one income tax liability for the year. Sec. 1503(a); 26 C.F.R. sec. 1.1502-2(a) (2019). Each member of a consolidated group is severally liable for the income ta

Belmont Interests Inc., Petitioner T.C. Memo. 2022-98 · 2022

Investment Basis Adjustments and Excess Loss Accounts Section 1501 allows affiliated corporations to join together to file a single consolidated return.

Kevin Scott Millen, Petitioner · 2019

d no effective date. The CDP hearing was held as scheduled on May 15, 2018. The SO asked petitioner to clarify some entries on his recently submitted 2015 return. He inter- 2Under the Patient Protection and Affordable Care Act, Pub. L. No. 111- 148, sec. 1501(b), 124 Stat. at 244-249 (2010) (codified at sec. 5000A), a taxpayer accrues an ISRP liability ifhe or she fails to maintain adequate health insurance coverage (called "minimum essential coverage") for a particular year. M sec. 5000A(a), (f

Steven A. McGuire & Robin L. McGuire, Petitioners · 2017

at 242; sec. 5000A; ACA sec. 1401, 124 Stat. at 213; sec. 36B; ACA sec. 1311, 124 Stat. at 173. The individual mandate is enforced by the imposition ofa penalty on individuals who do not maintain qualifying health insurance coverage. Sec. 5000A; ACA sec. 1501. The exchanges are health insurance markets that are administered by

Applied Research Associates, Inc. and Affiliate, Petitioners · 2014

See also Norwest Corp.

Applied Research Associates, Inc. & Affiliate v. Commissioner 143 T.C. 310 · 2014

esearch and Oak Crest constituted an affiliated group as defined by section 1504(a). Applied Research was the common parent. See sec. 1504(a). The affiliated group filed consolidated Federal income tax returns for both years involved as permitted by section 1501. Section 1503(a) provides that in any case in which a consolidated return is made, the tax shall be determined in accordance with the regulations promulgated under section 1502. Section 1502 provides that the Secretary shall prescribe su

State Farm Mutual Automobile Insurance Company & Subsidiaries, Petitioner 130 T.C. No. 16 · 2008

Section 1501 permits groups with both life and nonlife members to file consolidated returns if an appropriate election is made under section 1504(c) . See State Farm Mut . Auto . Ins . Co . v . Commissioner , 119 T .C . 342, 345-346 (2002) (State Farm I), affd . 105 Fed . Appx . 67 (7th Cir . 2004), for a more detailed background on life-nonlife co

State Farm Mutual Automobile Insurance & Subsidiaries v. Commissioner 130 T.C. 263 · 2008

Section 1501 permits groups with both life and nonlife members to file consolidated returns if an appropriate election is made under section 1504(c). See State Farm Mut. Auto. Ins. Co. v. Commissioner, 119 T.C. 342, 345-346 (2002) (State Farm I), affd. 105 Fed. Appx. 67 (7th Cir. 2004), for a more detailed background on life-nonlife consolidated re

State Farm Mutual Automobile Insurance Company and Subsidiaries, Petitioner 119 T.C. No. 21 · 2002

In general, section 1501 grants to affiliated groups the privilege of filing consolidated returns, a privilege in which groups containing both life and nonlife members may share if an appropriate election is made under section 1504(c).

State Farm Mutual Automobile Insurance v. Commissioner 119 T.C. 342 · 2002

In general, section 1501 grants to affiliated groups the privilege of filing consolidated returns, a privilege in which groups containing both life and nonlife members may share if an appropriate election is made under section 1504(c).

Sunoco, Inc. v. Commissioner 118 T.C. 181 · 2002

in issue, petitioner was the common parent of an affiliated group of corporations, as defined in section 1504(a), and it filed a consolidated Federal income tax return on behalf of itself and the other members of the affiliated group as permitted by section 1501. At all times material to this case, petitioner and the other members of its affiliated group engaged in the business of acquiring and developing oil, gas, and other energy properties, of refining or otherwise preparing the natural resou

General Motors Corporation and Subsidiaries, Petitioner 112 T.C. No. 19 · 1999

All members of the affiliated group must consent to the consolidated return regulations prescribed under section 1502 prior to the last day prescribed by law for the filing of a consolidated return. See id. Filing a consolidated return was considered such consent. See id. Section 1502 provided: The Secretary shall prescribe such regulati

General Motors Corp. & Subsidiaries v. Commissioner 112 T.C. 270 · 1999

All members of the affiliated group must consent to the consolidated return regulations prescribed under section 1502 prior to the last day prescribed by law for the filing of a consolidated return. See id. Filing a consolidated return was considered such consent. See id. Section 1502 provided: The Secretary shall prescribe such regulati

Intermet Corporation & Subsidiaries, Petitioner 111 T.C. No. 16 · 1998

As we see it, petitioner's position ignores those regulations. Section 1.1502-21A(f), Income Tax Regs., provides the exclusive method for computing the NOL of a consolidated group. The computation of the CNOL under section 1.1502-21A(f), Income Tax Regs., begins with the computation of each member's separate taxable income under section

Intermet Corp. v. Commissioner 111 T.C. 294 · 1998

As we see it, petitioner’s position ignores those regulations. Section 1.1502-21A(f), Income Tax Regs., provides the exclusive method for computing the NOL of a consolidated group. The computation of the CNOL under section 1.1502-21A(f), Income Tax Regs., begins with the computation of each member’s separate taxable income under section

Alumax Inc. and Consolidated Subsidiaries, Petitioner 109 T.C. No. 8 · 1997

Consolidation Section 1501 grants an affiliated group of corporations the privilege of filing a consolidated return.

Alumax Inc. v. Commissioner 109 T.C. 133 · 1997

Consolidation Section 1501 grants an affiliated group of corporations the privilege of filing a consolidated return.

Regal, Inc. v. Commissioner 53 T.C. 261 · 1969

Milavetz & Gallop v. United States · Cir.

Georgia-Pacific Corp. v. Commissioner 63 T.C. 790 · 1975

Wallace v. Rogers 513 F.3d 212 · Cir.

Denis v. Attorney General of the United States 633 F.3d 201 · Cir.

Norwest Corp. v. Commissioner 111 T.C. 105 · 1998

Amorient, Inc. v. Commissioner 103 T.C. 161 · 1994

Southern California Savings & Loan Ass'n v. Commissioner 95 T.C. 35 · 1990

Certified Grocers of California, Ltd. v. Commissioner 88 T.C. 238 · 1987

Century Data Systems, Inc. v. Commissioner 86 T.C. 157 · 1986

Craigie, Inc. v. Commissioner 84 T.C. 466 · 1985

Woods Investment Co. v. Commissioner 85 T.C. 274 · 1985

Century Data Systems, Inc. v. Commissioner 80 T.C. 529 · 1983

Jim Burch & Associates, Inc. v. Commissioner 76 T.C. 202 · 1981

Globe Products Corp. v. Commissioner 72 T.C. 609 · 1979

Wolter Construction Co. v. Commissioner 68 T.C. 39 · 1977

Covil Insulation Co. v. Commissioner 65 T.C. 364 · 1975

Daron Industries, Inc. v. Commissioner 62 T.C. 847 · 1974

Davis Bros. Restaurant, Inc. v. Commissioner 60 T.C. 525 · 1973

Intervest Enterprises, Inc. v. Commissioner 59 T.C. 91 · 1972

In Re Bartle 560 F.3d 724 · Cir.

Buckeye Countrymark, Inc. v. Commissioner 103 T.C. 547 · 1994

Stamos v. Commissioner 95 T.C. 624 · 1990

Warsaw Photographic Associates, Inc. v. Commissioner 84 T.C. 21 · 1985

First National Bank v. Commissioner 83 T.C. 202 · 1984

Gottesman & Co. v. Commissioner 77 T.C. 1149 · 1981

Johnson v. Commissioner 74 T.C. 1057 · 1980

Anderson v. Commissioner 67 T.C. 522 · 1976

Salem Packing Co. v. Commissioner 56 T.C. 131 · 1971

Nibur Building Corp. v. Commissioner 54 T.C. 835 · 1970

General Manufacturing Corp. v. Commissioner 44 T.C. 513 · 1965

Ray Engineering Co. v. Commissioner 42 T.C. 1120 · 1964

Landy Towel & Linen Service, Inc. v. Commissioner 38 T.C. 296 · 1962

Commercial Shearing & Stamping Co. v. Commissioner 36 T.C. 433 · 1961

Addison v. Seaver 540 F.3d 805 · Cir.

Thomas More Law Center v. Obama 651 F.3d 529 · Cir.

United Dominion v. United States · Cir.

Liberty University v. Timothy Geithner · Cir.

Intermet v. CIR · Cir.

Aeroquip-Vickers v. CIR · Cir.

Thomas More Law Center v. Barack Obama · Cir.

John Bartle v. United States · Cir.

Gary Wayne Colsen v. United States · Cir.

Lance Addison v. Randall Seaver · Cir.

United States v. Abraham Fisch 851 F.3d 402 · Cir.

Rodriguez v. Fed. Deposit Ins. Corp. (In Re United W. Bancorp, Inc.) 893 F.3d 716 · Cir.

Rodriguez v. Fed. Deposit Ins. Corp. (In Re United W. Bancorp, Inc.) 914 F.3d 1262 · Cir.

State of Texas v. USA 945 F.3d 355 · Cir.

State of Texas v. USA · Cir.

Agustin Valenzuela Gallardo v. William Barr 968 F.3d 1053 · Cir.

Liberty University v. Timothy Geithner · Cir.

Jean Pugin v. Merrick Garland · Cir.

In re: Howard D. Juntoff · Cir.

United Dominion Industries, Incorporated v. United States 208 F.3d 452 · Cir.

Intermet Corporation & Subsidiaries v. Commissioner of Internal Revenue 209 F.3d 901 · Cir.

Aeroquip-Vickers, Inc. And Subsidiaries, F/k/a Trinova Corp. And Subsidiaries v. Commissioner of Internal Revenue 347 F.3d 173 · Cir.

In Re: Gary Wayne Colsen, Debtor. Gary Wayne Colsen v. United States of America, (Internal Revenue Service) 446 F.3d 836 · Cir.

State Farm Mutual Automobile Insurance v. Commissioner 105 F. App'x 67 · Cir.

§1501 — Privilege to file consolidated returns

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