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INVESTORS DIVERSIFIED SERVICES, INC. v. U. S.

No. 245-72.

575 F.2d 843 (1978)

INVESTORS DIVERSIFIED SERVICES, INC. v. The UNITED STATES.

United States Court of Claims.

April 19, 1978.

Attorney(s) appearing for the Case

David W. Richmond, Washington, D.C., attorney of record, for plaintiff. Barron K. Grier, Robert L. Moore, II, and Miller & Chevalier, Washington, D.C., of counsel.

Kenneth R. Boiarsky, Washington, D.C., with whom was Asst. Atty. Gen. M. Carr Ferguson, Washington, D.C., for defendant. Theodore D. Peyser, Washington, D.C., of counsel.

Before DAVIS, KASHIWA and KUNZIG, Judges.

OPINION

DAVIS, Judge.

For the years 1964 and 1965, plaintiff, Investors Diversified Services (IDS), filed consolidated income tax returns on behalf of an affiliated group of which it was the common parent. One of the members of the group was Investors Syndicate of America, Inc. (ISA), a wholly owned subsidiary of IDS. ISA was a face-amount certificate company registered under the Investment Company Act of 1940, 15 U.S.C. § 80a-28 (1970), and was subject...

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