Woods Inv. Co. v. Commissioner
United States Tax Court
During all relevant years (1966-78), petitioner was the parent of four wholly owned subsidiaries with which it filed consolidated Federal income tax returns. The subsidiaries used accelerated methods to depreciate their business property.
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During all relevant years (1966-78), petitioner was the parent of four wholly owned subsidiaries with which it filed consolidated Federal income tax returns. The subsidiaries used accelerated methods to depreciate their business property. Petitioner sold all of its stock in the subsidiaries on Dec. 13, 1978. In determining its gain from the sale, petitioner determined its basis in the subsidiaries' stock by reference to the subsidiaries' earnings and profits pursuant to sec. 1.1502-32, Income Tax Regs. In computing the earnings and profits of the subsidiaries, petitioner used the amount of…
1Opinion of the Court
OPINION
Fay, Judge:
Respondent determined a deficiency of $3,211,019 in petitioner’s 1978 Federal income tax. The only issue is whether petitioner properly computed the basis in its subsidiaries’ stock in reporting gain from the sale of the stock.
The facts have been fully stipulated and are so found.
Petitioner Woods Investment Co., a Delaware corporation, had its principal office in Oklahoma City, Oklahoma, at the time it filed the petition herein.
Petitioner is a calendar year taxpayer using the accrual method of accounting. From the date of its formation in 1966 through its taxable year ended…
2Cases cited10 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Commissioner v. HansenSupreme Court of the United States · 1959
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
- United States v. New YorkSupreme Court of the United States · 1942
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- Exxon Corp. v. CommissionerUnited States Tax Court · 1994
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