Legal Opinion

Continental Grain Co. v. Commissioner

United States Tax Court

Decided April 10, 1989No. Docket Nos. 34157-84; 34163-84; 34164-84UnpublishedCited by 1 opinion

In Continental Grain Co., Transferee v. Commissioner,T.C. Memo. 1988-577, we found that the subsidiary (Polo) of petitioner's transferor (Allied) was insolvent for purposes of section 332 on the date of Polo's liquidation. Respondent thereafter moved that we reconsider and revise that opinion, and vacate our decision for petitioner. Held: On the date of its liquidation, Polo was indebted to Allied for interest on intercompany debt.

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In Continental Grain Co., Transferee v. Commissioner,T.C. Memo. 1988-577, we found that the subsidiary (Polo) of petitioner's transferor (Allied) was insolvent for purposes of section 332 on the date of Polo's liquidation. Respondent thereafter moved that we reconsider and revise that opinion, and vacate our decision for petitioner. Held: On the date of its liquidation, Polo was indebted to Allied for interest on intercompany debt. Held further: petitioner is not bound by evidence of fair market value submitted in its behalf which we find unreliable. Held further: respondent's motion will be…

1Opinion of the Court

CONTINENTAL GRAIN COMPANY, TRANSFEREE OF ALLIED MILLS, INC., AS SUCCESSOR BY MERGER TO ELM CREEK ALFALFA MILLS, INC., ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Continental Grain Co. v. Commissioner

Docket Nos. 34157-84; 34163-84; 34164-84.

United States Tax Court

T.C. Memo 1989-155; 1989 Tax Ct. Memo LEXIS 155; 57 T.C.M. (CCH) 57; T.C.M. (RIA) 89155;

April 10, 1989.

In Continental Grain Co., Transferee v. Commissioner,T.C. Memo. 1988-577, we found that the subsidiary (Polo) of petitioner's transferor (Allied) was insolvent for purposes of section 332 on the date of…

2Cases cited5 opinions

  1. Jasionowski v. CommissionerUnited States Tax Court · 1976
  2. Lakefront Realty Corp. v. LorenzIllinois Supreme Court · 1960
  3. Spaulding Bakeries, Inc. v. CommissionerUnited States Tax Court · 1957
  4. Commissioner of Internal Revenue v. Spaulding Bakeries IncorporatedCourt of Appeals for the Second Circuit · 1958
  5. Continental Grain Co. v. CommissionerUnited States Tax Court · 1988

3Cited by1 opinion

  1. Dorsey v. CommissionerUnited States Tax Court · 1990

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