Legal Opinion
Textron, Inc. v. United States
Court of Appeals for the First Circuit
Decided June 23, 1977No. 76-1446PublishedCited by 13 opinions
1Opinion of the Court
COFFIN, Chief Judge.
In the 1950’s Textron, Inc. had a wholly owned subsidiary, Hawaiian Textron, Inc. (Hawaiian). Hawaiian ran passenger ships between Hawaii and the West Coast and lost enormous sums of money in the process. In 1959, creditors foreclosed on its assets. Textron’s six million dollar investment in Hawaiian’s stock and debt became worthless, with one possible exception: Hawaiian’s huge losses could be used to reduce its taxable corporate income in future years. Because Hawaiian had no income prospects, a second, profitable corporation would have to be merged into Hawaiian’s empty…
2Cases cited6 opinions
- Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
- West Seattle National Bank of Seattle v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1961
- Keeney v. CommissionerCourt of Appeals for the Second Circuit · 1940
- Marwais Steel Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1965
- Lan Jen Chu and Grace Y. P. Chu v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1973
1 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Estate of Guy L. Mann, Deceased. Suzanne Mann Duval, Administratrix v. United StatesCourt of Appeals for the Fifth Circuit · 1984
- Official Committee of Unsecured Creditors v. PSS Steamship Co. (In Re Prudential Lines, Inc.)United States Bankruptcy Court, S.D. New York · 1989
- Exxon Corporation v. The United StatesCourt of Appeals for the Federal Circuit · 1986
- The El Paso Company, and El Paso Natural Gas Company v. The United StatesCourt of Appeals for the Federal Circuit · 1982
- Danbury, Inc. v. OliveDistrict Court, Virgin Islands · 1986
8 more not listed; retrieve them via the Exa API.