American Mfg. Co. v. Commissioner
United States Tax Court
Corporation A owned 100 percent of the stock of corporation B, an American subsidiary, and corporation C, a foreign subsidiary. Corporation B sold its operating assets to corporation C for cash. Subsequent thereto, corporation B owned only cash and receivables, which it distributed in liquidation to its parent, corporation A. No sec. 367 clearance was obtained for the transaction involving the foreign subsidiary.
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Corporation A owned 100 percent of the stock of corporation B, an American subsidiary, and corporation C, a foreign subsidiary. Corporation B sold its operating assets to corporation C for cash. Subsequent thereto, corporation B owned only cash and receivables, which it distributed in liquidation to its parent, corporation A. No sec. 367 clearance was obtained for the transaction involving the foreign subsidiary. Held, the various steps, including the liquidation of corporation B, were integral parts of a reorganization of corporation B within the purview of sec. 368(a)(1)(D) and the gain to…
1Opinion of the Court
American Manufacturing Company, Inc. (Successor by Merger to Safety Industries, Inc.; Successor by Liquidation to Pintsch Compressing Corp.), Petitioner v. Commissioner of Internal Revenue, Respondent; American Manufacturing Company, Inc. (Successor by Merger to Safety Industries, Inc.), Petitioner v. Commissioner of Internal Revenue, Respondent
American Mfg. Co. v. Commissioner
Docket Nos. 4027-65, 4028-65
United States Tax Court
55 T.C. 204; 1970 U.S. Tax Ct. LEXIS 37;
October 29, 1970, Filed
Decision will be entered for the respondent in docket No. 4027-65.
Decision will be entered under Rule 50…
Also in this document: Concurring in part, dissenting in part; Dissent.
2Cases cited36 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Bazley v. CommissionerSupreme Court of the United States · 1947
- J. E. Davant and Kathryn Davant v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. J. E. Davant and Kathryn DavantCourt of Appeals for the Fifth Circuit · 1966
- Lewis v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1949
- South Texas Rice Warehouse Co. v. CommissionerUnited States Tax Court · 1965
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