D'Arcy-MacManus & Masius, Inc. v. Commissioner
United States Tax Court
In 1967 WWB-Cal acquired all the assets of HSI, a corporation which had suffered net operating losses in several of its preceding taxable years. Held, the acquisition was not made for the principal purpose of evading or avoiding Federal income tax.
1Opinion of the Court
Sterrett, Judge:
The respondent determined deficiencies in the Federal income taxes of MacManus, John & Adams, Inc.1 (docket No. 8593-71), of which petitioner is the successor by a subsequent consolidation of MacManus, John & Adams, Inc., with D’Arcy Advertising Co. to form D’Arcy, MacManus, Intermarco, Inc., and an even later merger of Masius, Wynne-Williams, Inc., into petitioner, and in the Federal income taxes of West, Weir & Bartel, Inc. (Cal.), which was merged and liquidated into MacManus, John & Adams, Inc., and hence of petitioner, against whom transferee liability is asserted, as…
2Cases cited10 opinions
- Commodores Point Terminal Corp. v. CommissionerUnited States Tax Court · 1948
- Baton Rouge Supply Co. v. CommissionerUnited States Tax Court · 1961
- Vulcan Materials Company v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- The Zanesville Investment Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1964
- Glen Raven Mills, Inc. v. CommissionerUnited States Tax Court · 1972
5 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- VGS Corp. v. CommissionerUnited States Tax Court · 1977
- Capri, Inc. v. CommissionerUnited States Tax Court · 1975
- Jupiter Corp. v. United StatesUnited States Court of Claims · 1983
- U.S. Shelter Corp. v. United StatesUnited States Court of Claims · 1987
- Daytona Beach Kennel Club, Inc. v. CommissionerUnited States Tax Court · 1978
18 more not listed; retrieve them via the Exa API.