Textron Inc. v. Commissioner
United States Tax Court
A filed a consolidated return with its wholly-owned subsidiary (PR) in 1977. During that year, A distributed a note to PR in redemption of PR's shares in A. In 1985, P acquired more than 80 percent of the stock of A, and thereupon A and PR became members of P's consolidated group. In 1987, A redeemed the note from PR.
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A filed a consolidated return with its wholly-owned subsidiary (PR) in 1977. During that year, A distributed a note to PR in redemption of PR's shares in A. In 1985, P acquired more than 80 percent of the stock of A, and thereupon A and PR became members of P's consolidated group. In 1987, A redeemed the note from PR. Later that year, PR liquidated into A. HELD: Under sec. 1.1502-14(d)(4), Income Tax Regs., P may not take a deduction in 1987 for the capital loss PR realized on the redemption of A's note.
1Opinion of the Court
OPINION
Laro, Judge:
This case is before the Court fully stipulated. See Rule 122. Petitioner petitioned the Court to redetermine respondent’s determination of deficiencies in Federal income tax for its taxable years ended January 2, 1988, December 31, 1988, December 30, 1989, December 29, 1990, December 28, 1991, and January 2, 1993, in the amounts of $5,083,201, $1,783,938, $244,211, $1,152,171, $14,011,513, and $68,811, respectively.
We decide herein whether petitioner is entitled to a claimed $14,934,745 capital loss for the taxable year ended January 2, 1988 (1987 taxable year).1 We hold it…
2Cases cited11 opinions
- Brotherhood of Railroad Trainmen v. Baltimore & Ohio RailroadSupreme Court of the United States · 1947
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- Albertson's, Inc., Petitioner-Appellant-Cross-Appellee v. Commissioner of Internal Revenue, Respondent-Appellee-Cross-AppellantCourt of Appeals for the Ninth Circuit · 1994
- BUNNEY v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2000
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