Capital Blue Cross & Subsidiaries v. Comm'r
United States Tax Court
As part of its statutory conversion under sec. 1012(a) and (b) of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2390, from a tax-exempt to a taxable entity, petitioner generally was entitled to step up its tax basis in its assets to their Jan. 1, 1987, fair market value. Held, among other things, for 1994: (1) The basis step-up provision of sec. 1012(c)(3)(A)(ii) of the Tax Reform Act of 1986, Pub.
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As part of its statutory conversion under sec. 1012(a) and (b) of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2390, from a tax-exempt to a taxable entity, petitioner generally was entitled to step up its tax basis in its assets to their Jan. 1, 1987, fair market value. Held, among other things, for 1994: (1) The basis step-up provision of sec. 1012(c)(3)(A)(ii) of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2394, is not limited to "sale or exchange" transactions; and (2) because petitioner's valuation of its health insurance group contracts did not constitute a…
1Opinion of the Court
CAPITAL BLUE CROSS AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Capital Blue Cross & Subsidiaries v. Comm'r
No. 13322-01
United States Tax Court
122 T.C. 224; 2004 U.S. Tax Ct. LEXIS 11; 122 T.C. No. 11;
March 12, 2004, Filed
Decision entered for Respondent.
As part of its statutory conversion under sec. 1012(a) and(b) of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2390, from a tax-exempt to a taxable entity, petitioner
generally was entitled to step up its tax basis in its assets to
their Jan. 1, 1987, fair market value.
Held, among other things, for 1994: (1)…
2Cases cited36 opinions
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Robinson v. Shell Oil Co.Supreme Court of the United States · 1997
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- Green v. Bock Laundry MacHine Co.Supreme Court of the United States · 1989
- Idahoan Fresh v. Advantage ProduceCourt of Appeals for the Third Circuit · 1998
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