Clarksdale Rubber Co. v. Commissioner
United States Tax Court
Petitioner, a financially distressed producer of rubber products, was acquired by Cooper, who leased petitioner's assets and transferred its production and sales activities to a newly formed sister subsidiary until petitioner's financial position was improved. Cooper then caused the production and sales activities to be returned to petitioner and it continued the manufacture and sale of rubber products as before.
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Petitioner, a financially distressed producer of rubber products, was acquired by Cooper, who leased petitioner's assets and transferred its production and sales activities to a newly formed sister subsidiary until petitioner's financial position was improved. Cooper then caused the production and sales activities to be returned to petitioner and it continued the manufacture and sale of rubber products as before. Held: 1. Cooper did not purchase petitioner for the principal purpose of avoiding Federal income taxes. Sec. 269(a), I.R.C. 1954, inapplicable. 2. Libson Shops, Inc. v. Koehler, 353…
1Opinion of the Court
Clarksdale Rubber Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Clarksdale Rubber Co. v. Commissioner
Docket No. 663-64
United States Tax Court
45 T.C. 234; 1965 U.S. Tax Ct. LEXIS 8;
December 8, 1965, Filed
Decision will be entered under Rule 50.
Petitioner, a financially distressed producer of rubber products, was acquired by Cooper, who leased petitioner's assets and transferred its production and sales activities to a newly formed sister subsidiary until petitioner's financial position was improved. Cooper then caused the production and sales activities to be returned to…
2Cases cited41 opinions
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Seaboard Commercial Corp. v. CommissionerUnited States Tax Court · 1957
- Mill Ridge Coal Company v. George D. Patterson, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
- Commissioner of Internal Revenue v. Goodwyn Crockery CompanyCourt of Appeals for the Sixth Circuit · 1963
- Humacid Co. v. CommissionerUnited States Tax Court · 1964
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