Garber Indus. Holding Co. v. Comm'r
United States Tax Court
P, a closely held corporation, is the parent of an affiliated group that files consolidated Federal income tax returns. In April 1998, A sold all of his P shares to his brother, B. As a result of that sale, B's percentage ownership of P increased by more than 50 percentage points. On its consolidated income tax return for 1998, P claimed a net operating loss (NOL) deduction of $ 808,935 for regular tax purposes and $ 735,783 for alternative minimum tax (AMT) purposes.
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P, a closely held corporation, is the parent of an affiliated group that files consolidated Federal income tax returns. In April 1998, A sold all of his P shares to his brother, B. As a result of that sale, B's percentage ownership of P increased by more than 50 percentage points. On its consolidated income tax return for 1998, P claimed a net operating loss (NOL) deduction of $ 808,935 for regular tax purposes and $ 735,783 for alternative minimum tax (AMT) purposes. R determined that the 1998 transaction between A and B resulted in an ownership change with respect to P within the meaning of…
1Opinion of the Court
GARBER INDUSTRIES HOLDING CO., INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Garber Indus. Holding Co. v. Comm'r
No. 10871-01
United States Tax Court
124 T.C. 1; 2005 U.S. Tax Ct. LEXIS 1; 124 T.C. No. 1;
January 25, 2005, Filed
Judgment entered for respondent and in accordance with parties' stipulations as to correct amount of petitioner's income tax deficiencies.
P, a closely held corporation, is the parent of an
affiliated group that files consolidated Federal income tax
returns. In April 1998, A sold all of his P shares to his
brother, B. As a result of that sale, B's percentage…
2Cases cited8 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- 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
- Jonson v. Comm'rUnited States Tax Court · 2002
- Jonson v. CommissionerCourt of Appeals for the Tenth Circuit · 2003
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