GENERAL DYNAMICS CORP. & SUBS. v. COMMISSIONER

Docket Nos. 19202-94, 19203-94.

108 T.C. 107 (1997)

GENERAL DYNAMICS CORPORATION & SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT GENERAL DYNAMICS FOREIGN SALES CORP., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 26, 1997.


Attorney(s) appearing for the Case

David C. Bohan, Richard T. Franch, James M. Lynch, Philip A. Stoffregen, David D. Baier, Scott Schaner, Gregory S. Gallopoulos, and Debbie L. Berman, for petitioner in docket No. 19202-94.

David C. Bohan, James M. Lynch, Philip A. Stoffregen, and David D. Baier, for petitioner in docket No. 19203-94.

William H. Quealy, Jr., Alice M. Harbutte, Jeffrey A. Hatfield, Thomas C. Pliske, and William T. Derick, for respondent.


GERBER, Judge:

General Dynamics Corp. and its consolidated subsidiaries (GENDYN) (docket No. 19202-94) and its foreign sales corporation, General Dynamics Foreign Sales Corp. (GENDYN/FSC) (docket No. 19203-94), are petitioners in these consolidated cases. Respondent determined corporate income tax deficiencies for GENDYN in the amounts of $26,118,976 and $291,218,973 for its 1985 and 1986 taxable years, respectively. With respect to GENDYN/FSC, respondent determined...

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