Union Oil Co. v. Commissioner
United States Tax Court
On Apr. 25, 1983, P1, the common parent of P Group, became a party to a reverse acquisition as specified in sec. 1.1502-75(d)(3)(i), Income Tax Regs. As a result thereof, P1 became a subsidiary of P2, the new common parent of P Group. In 1990, respondent issued a notice of deficiency to P1 for the P Group for deficiencies in its income tax liabilities for taxable years preceding the reverse acquisition.
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On Apr. 25, 1983, P1, the common parent of P Group, became a party to a reverse acquisition as specified in sec. 1.1502-75(d)(3)(i), Income Tax Regs. As a result thereof, P1 became a subsidiary of P2, the new common parent of P Group. In 1990, respondent issued a notice of deficiency to P1 for the P Group for deficiencies in its income tax liabilities for taxable years preceding the reverse acquisition. P1 filed a petition for redetermination of these deficiencies, and thereafter the Court entered a decision pursuant to a stipulation of the parties. P1 then filed a motion to vacate the…
1Opinion of the Court
OPINION
Wright, Judge:
This matter is before the Court on petitioner’s motion to vacate the decision of this Court entered on December 1, 1992, pursuant to a stipulation of the parties. For the reasons set forth herein, we hold that the Court has jurisdiction over this matter and that petitioner’s motion to vacate the decision of this Court entered on December 1, 1992, must be denied. The pertinent facts are not in dispute.
Petitioner was incorporated under the laws of California on October 17, 1890, and was, until April 25, 1983, the top-tier corporation of a group of affiliated corporations…
2Cases cited6 opinions
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