FMC Corp. v. Comm'r
United States Tax Court
P paid the investment banking firm of Goldman, Sachs & Co. (G) approximately $ 17.5 million to advise it financially on a recapitalization. One of G's employees disclosed non-public information on the recapitalization to various Wall Street professionals, including IB. IB traded P's stock on the basis of this non-public information.
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P paid the investment banking firm of Goldman, Sachs & Co. (G) approximately $ 17.5 million to advise it financially on a recapitalization. One of G's employees disclosed non-public information on the recapitalization to various Wall Street professionals, including IB. IB traded P's stock on the basis of this non-public information. P first announced that it would redeem each share of P stock held by the public in exchange for cash of $ 70 and one share of stock in the new company. P later increased the cash payment to $ 80 per share and effectuated the recapitalization at that price. P's…
1Opinion of the Court
FMC CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
FMC Corp. v. Comm'r
No. 2317-00
United States Tax Court
T.C. Memo 2001-298; 2001 Tax Ct. Memo LEXIS 336; 82 T.C.M. (CCH) 884; T.C.M. (RIA) 54543;
November 8, 2001, Filed
FMC Corp. v. Boesky (In re Boesky Sec. Litig.), 36 F.3d 255, 1994 U.S. App. LEXIS 27002, (2d Cir. N.Y. 1994)
Motion for summary judgment was granted; petitioner was collaterally estopped from claiming the referenced theft loss. Decision was entered for respondent.
P paid the investment banking firm of Goldman, Sachs & Co.
(G) approximately $…
2Cases cited25 opinions
- Matsushita Electric Industrial Co., Ltd. v. Zenith Radio CorporationSupreme Court of the United States · 1986
- Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
- Montana v. United StatesSupreme Court of the United States · 1979
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Chiarella v. United StatesSupreme Court of the United States · 1980
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