Interlake Corp. v. Commissioner
United States Tax Court
P, as the result of a restructuring transaction, became the successor common parent of a consolidated group of corporations (the group). A, the former common parent of the group, became a wholly owned subsidiary of P. P then distributed, pro rata, to its shareholders, all of the issued and outstanding common shares of A, which became, as a result of the spinoff, a separate publicly traded corporation.
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P, as the result of a restructuring transaction, became the successor common parent of a consolidated group of corporations (the group). A, the former common parent of the group, became a wholly owned subsidiary of P. P then distributed, pro rata, to its shareholders, all of the issued and outstanding common shares of A, which became, as a result of the spinoff, a separate publicly traded corporation. Subsequent to the restructuring transaction, P and the group incurred a consolidated net operating loss (CNOL). P filed an application under sec. 6411, I.R.C., for a tentative refund of income…
1Opinion of the Court
OPINION
WELLS, Judge: This matter is before the Court on the parties’ cross-motions for summary judgment pursuant to Rule 121(a). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Respondent determined deficiencies in the Federal income tax of Interlake Corp. and its consolidated subsidiaries as follows:
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After concessions by petitioner, only the deficiencies with respect to 1981 and 1984 remain in issue. We must decide whether…
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- Groetzinger v. CommissionerUnited States Tax Court · 1977
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