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GENERAL DYNAMICS CORP. v. COMMISSIONER

Docket Nos. 19202-94, 19203-94.

74 T.C.M. 632 (1997)

T.C. Memo. 1997-420

General Dynamics Corporation and Subsidiaries v. Commissioner. General Dynamics Foreign Sales Corp. v. Commissioner.

United States Tax Court.

Filed September 22, 1997.

Attorney(s) appearing for the Case

David C. Bohan, Chicago, Ill., Richard T. Franch, James M. Lynch, Philip A. Stoffregen, Francis J. Wirtz, David D. Baier, Lawrence S. Schaner, Gregory S. Gallopoulos, and Debbie L. Berman, for the petitioners. William H. Quealy, Jr., Alice M. Harbutte, Jeffrey A. Hatfield, Thomas C. Pliske, and William T. Derick, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

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/FOREIGN) (Docket No. 19203-94), are the 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...

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