Gerdau MacSteel, Inc. & Affiliated Subsidiaries v. Commissioner
United States Tax Court
Q and its subsidiaries are an affiliated group (Ps). During Ps' taxable year ended Oct. 31, 1997 (TYE 1997), Ps actively pursued Q's making of two sales expected to result in millions of dollars in taxable capital gains for TYE 1997 and TYE 1998. Ps' outside accountants (D), mindful of the expected gains, approached Ps with an idea that D promoted to create a multimillion-dollar tax loss to shelter the gains for Federal income tax purposes.
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Q and its subsidiaries are an affiliated group (Ps). During Ps' taxable year ended Oct. 31, 1997 (TYE 1997), Ps actively pursued Q's making of two sales expected to result in millions of dollars in taxable capital gains for TYE 1997 and TYE 1998. Ps' outside accountants (D), mindful of the expected gains, approached Ps with an idea that D promoted to create a multimillion-dollar tax loss to shelter the gains for Federal income tax purposes. Q has a group benefits plan under which Q provides health and welfare benefits to its eligible employees and their dependents. Q's subsidiaries included…
1Opinion of the Court
CONTENTS
FINDINGS OF FACT . 74
I. Preliminary Matters . 74
II. Quanex . 74
III. Petitioners’ Expectation of Realizing Millions of Dollars in Taxable Capital Gains During TYE 1997 and TYE 1998 ... 75
TV. The Plan . 76
A. Background . 76
B. Health Care Offerings . 76
C. Health Care Cost Management Strategies . 77
1. Background . 77
2. CS . 77
a. Background . 77
b. Quanex’s Introduction to CS . 78
c. CS Fee Arrangements . 79
V. D&T . 79
VI. Other Quanex Employees/Officers o co
A. Rose . OO
B. Parikh . 00
C. Royce . 00
VII. Liability Management Companies
A. Overview . oo K
B. Rev. Rul. 95-74 . oo to
C. D&T’s Matrix .…
2Cases cited57 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
52 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
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- Salem Financial, Inc. v. United StatesUnited States Court of Federal Claims · 2013
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