Georgia-Pacific Corp. v. Commissioner
United States Tax Court
Petitioner is the transferee of Colortype, against which a deficiency was assessed for 1968. Petitioner acquired all of Colortype's assets in a "C" reorganization on Jan. 8, 1969. Colortype and its wholly owned subsidiary, McDonald, filed consolidated returns for 1968 and prior years during which periods excess losses of McDonald were utilized in computing the group's consolidated income.
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Petitioner is the transferee of Colortype, against which a deficiency was assessed for 1968. Petitioner acquired all of Colortype's assets in a "C" reorganization on Jan. 8, 1969. Colortype and its wholly owned subsidiary, McDonald, filed consolidated returns for 1968 and prior years during which periods excess losses of McDonald were utilized in computing the group's consolidated income. The group did not file a consolidated return for the short period Jan. 1 to Jan. 7, 1969. Accordingly, Colortype is deemed to have disposed of its McDonald stock on Dec. 31, 1968. Held, upon the deemed…
1Opinion of the Court
Georgia-Pacific Corporation, Transferee, Petitioner v. Commissioner of Internal Revenue, Respondent
Georgia-Pacific Corp. v. Commissioner
Docket No. 9074-72
United States Tax Court
63 T.C. 790; 1975 U.S. Tax Ct. LEXIS 173;
March 31, 1975, Filed
Decision will be entered for the respondent.
Petitioner is the transferee of Colortype, against which a deficiency was assessed for 1968. Petitioner acquired all of Colortype's assets in a "C" reorganization on Jan. 8, 1969. Colortype and its wholly owned subsidiary, McDonald, filed consolidated returns for 1968 and prior years during which periods excess…
2Cases cited31 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Brewster v. GageSupreme Court of the United States · 1930
- Sanford v. CommissionerUnited States Tax Court · 1968
- William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
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