American Potash & Chemical Corporation v. The United States

LARAMORE, Judge.

This ease is before the court on Defendant’s Petition for Reconsideration of our decision issued July 17, 1968 (American Potash & Chemical Corp. v. United States, Ct.Cl., 399 F.2d 194), in which we denied defendant’s motion for summary judgment. Defendant has argued that plaintiff must use a carryover basis for the assets received in liquidation of its subsidiary, Wecco, because the acquisition of Wecco stock in a series of exchanges of stock for stock over a 14-month period either qualified as a C reorganization or, alternatively, because it failed to qualify under section…