26 U.S.C. § 1502
Regulations
The Secretary shall prescribe such regulations as he may deem necessary in order that the tax liability of any affiliated group of corporations making a consolidated return and of each corporation in the group, both during and after the period of affiliation, may be returned, determined, computed, assessed, collected, and adjusted, in such manner as clearly to reflect the income-tax liability and the various factors necessary for the determination of such liability, and in order to prevent avoidance of such tax liability. In carrying out the preceding sentence, the Secretary may prescribe rules that are different from the provisions of chapter 1 that would apply if such corporations filed separate returns.
Notes of Decisions
Cited in 31
cases, 1935–2020 · leading case: United Dominion Indus., Inc. v. United States, 532 U.S. 822 (2001).
United Dominion Indus., Inc. v. United States, 532 U.S. 822 (2001). “And finally, if the Government were to conclude that § 269 provided too little protection and that it simply could not live with the single-entity approach, the Treasury could exercise the authority provided by the Code, 26 U. S. C. § 1502 , and amend the consolidated return…”
Rodriguez v. Fed. Deposit Ins. Corp., 140 S. Ct. 713 (2020). “See 26 U.S.C. § 1502 ; 26 CFR § 1.1502-0 et seq.”
Duquesne Light Holdings Inc v. Comm'r of Internal Reven, 861 F.3d 396 (3rd Cir. 2017). “” 26 U.S.C. § 1502 . The possibility of separate treatment nonetheless creates the potential for the group to deflect its tax liability by using stock sales to claim a second deduction for a single loss at the subsidiary (such as a loss on the subsidiary’s sale of an asset).”
George Nichols, Iii, in His Capacity as Liquidator of Kentucky Cent. Life Ins. Co. v. United States, 260 F.3d 637 (6th Cir. 2001). “26 U.S.C. § 1502 . Section 1503 further provides: In any case in which a consolidated return is made or is required to be made, the tax shall be determined, computed, assessed, collected, and adjusted in accordance with the regulations under section 1502 prescribed before the…”
Caplin v. Marine Midland Grace Trust Co. of New York, 406 U.S. 416 (1972). “See 26 U. S. C. § 1502 . Section 1.1 of the Indenture gave Webb & Knapp authority to consider other companies as affiliates if it chose to do so.”
In Re G-1 Holdings Inc., 420 B.R. 216 (D.N.J. 2009). “See 26 U.S.C. § 1502 ; 26 C.F.R. § 1.1502-6 (a).”
United States v. Bond, 486 B.R. 9 (E.D.N.Y 2012). “102-77A(d) was enacted by the IRS pursuant to 26 U.S.C. § 1502 , which provides as follows: The Secretary shall prescribe such regulations as he may deem necessary in order that the tax liability of any affiliated group of corporations making a consolidated return and of each…”
The Falconwood Corp. v. United States, 422 F.3d 1339 (Fed. Cir. 2005). “ii We hold on the facts of this case that the regulations at issue leave no room for an application of the step transaction doctrine, where the Mocatta Group proceeded to Configuration B for an independent business purpose and was thereafter bound to follow the consolidated…”
Principal Life Ins. v. United States, 70 Fed. Cl. 144 (Fed. Cl. 2006). “Section 1502 broadly authorizes the Secretary to adopt consolidated return regulations as he “may deem necessary in order that the tax liability of any affiliated group of corporations making a consolidated return and of each corporation in the group .”
Conyer v. United States, 80 F.2d 292 (6th Cir. 1935). “( 26 U.S.C.A. § 1502 ). This section makes no provision for seizure, and it has been held that seizure cannot be made thereunder.”
Abston v. Comm'r, 691 F.3d 992 (8th Cir. 2012). “See 26 U.S.C. § 1502 (rules for filing consolidated returns).”
Electrolux Holdings, Inc. v. United States, 71 Fed. Cl. 748 (Fed. Cl. 2006). “§ 6511 (c)(1) (subject to certain limitations, refund claims on an assessment may be filed six months after the expiration of an agreed extension of the period of limitation). On July 6, 2001, the United States Court of Appeals for the Federal Circuit held that the Loss…”
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