Legal Opinion
General Electric Co. v. United States
United States Court of Claims
Decided August 16, 1983No. 395-78PublishedCited by 3 opinions
1Opinion of the Court
OPINION
KOZINSKI, Chief Judge.
Plaintiff General Electric challenges the Commissioner’s reallocation of losses suffered on the sale of certain assets. GE had acquired these assets through the tax free liquidation of a subsidiary. GE claimed the losses and the Commissioner reallocated them to the subsidiary. The parties have stipulated the facts and cross-moved for judgment.
FACTS
Taxpayer is a large manufacturer of electrical products. In the late 1950’s it established Caribe General Electric, Inc., the first of several wholly owned subsidiaries that were to perform manufacturing activities in…
2Cases cited8 opinions
- Young & Rubicam, Inc. v. The United StatesUnited States Court of Claims · 1969
- Central Cuba Sugar Co. v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. Central Cuba Sugar CoCourt of Appeals for the Second Circuit · 1952
- Francis L. Rooney and Irene Rooney v. United StatesCourt of Appeals for the Ninth Circuit · 1962
- E. I. du Pont de Nemours & Co. v. United StatesUnited States Court of Claims · 1979
- Northwestern National Bank of Minneapolis v. United StatesCourt of Appeals for the Eighth Circuit · 1977
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3Cited by3 opinions
- Merck & Co. v. United StatesUnited States Court of Claims · 1991
- Kellogg Co. v. OlsenTennessee Supreme Court · 1984
- Pikeville Coal Co. v. United StatesUnited States Court of Federal Claims · 1997