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Regal, Inc. v. Commissioner of Internal Revenue

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT


decided: November 17, 1970.

REGAL, INCORPORATED, PETITIONER -APPELLANT,
v.
COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLEE

Moore, Friendly and Adams,*fn* Circuit Judges.

Author: Per Curiam

The issues here presented are succinctly stated by the Tax Court as follows:

"The Commissioner determined a deficiency in the income tax of petitioner for the taxable year ended January 31, 1965 in the amount of $64,347.39. At issue is whether petitioner and its subsidiaries were required to file a consolidated Federal income tax return for their taxable year ended January 31, 1965 solely because they elected to file a consolidated Federal income tax return for the previous taxable year."

Appellant Regal, Inc. claims that Treasury Regulation 1.1502-11A is invalid.*fn1 This regulation provides, with appropriate exceptions that once an affiliated group of corporations elects to file a consolidated return, such group must continue to file on a consolidated basis until permission of the Commissioner of Internal Revenue be obtained to make a change. We affirm the decision of the Tax Court upon the facts and for the reasons stated by Judge Raum in his opinion below, 53 T.C. 261 filed November 17, 1969.


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