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COMPUTER SCIENCES CORP. v. COMMISSIONER

Docket No. 3382-70.

63 T.C. 327 (1974)

COMPUTER SCIENCES CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 16, 1974.

Attorney(s) appearing for the Case

James S. Cline, James B. Isaacs, and John E. Gates, for the petitioner.

Sheldon M. Sisson, for the respondent.

SCOTT, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the taxable year ended April 1, 1966, in the amount of $694,248. Some of the issues have been disposed of by agreement of the parties, leaving for decision whether Computax Corp., petitioner's wholly owned subsidiary engaged in the business of preparing State and Federal income tax returns, was a collapsible corporation within the meaning of section 341, I.R.C. 1954,

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