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ERWIN PROPERTIES, INC. v. COMMISSIONER

Docket No. 4024-63.

43 T.C. 888 (1965)

ERWIN PROPERTIES, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 24, 1965.

Attorney(s) appearing for the Case

Jules Silk, for the petitioner.

Dennis C. DeBerry, for the respondent.

OPINION

BLACK, Judge:

Petitioner is a corporation which became a member of an affiliated group of corporations on May 1, 1959. Petitioner had previously filed its income tax returns on a calendar year basis. The affiliated group of corporations filed a consolidated return for the fiscal year ended April 30, 1960, in 1960. Pursuant to section 1.1502-13(g), Income Tax Regs., petitioner filed a return on June 6, 1960, for the short period January 1,...

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