Pepi, Inc. v. Commissioner
United States Tax Court
The Industrial Expansion Committee of a group of American Philips corporations decided in March of 1957 to have one of the corporations in the group merge with A. Hollander & Son, Inc. in such a way that the Philips companies would acquire control of Hollander. This merger was effected in July 1957. Hollander had a two-million-dollar-plus net operating loss carryover.
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The Industrial Expansion Committee of a group of American Philips corporations decided in March of 1957 to have one of the corporations in the group merge with A. Hollander & Son, Inc. in such a way that the Philips companies would acquire control of Hollander. This merger was effected in July 1957. Hollander had a two-million-dollar-plus net operating loss carryover. The loss resulted from a fur business which it had disposed of in the latter half of 1956. Respondent determined the principal purpose for the acquisition was to secure the benefit of a deduction for the loss carryover. In…
1Opinion of the Court
PEPI, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Pepi, Inc. v. Commissioner
Docket No. 276-67
United States Tax Court
52 T.C. 854; 1969 U.S. Tax Ct. LEXIS 70;
August 25, 1969, Filed
Decision will be entered under Rule 50.
The Industrial Expansion Committee of a group of American Philips corporations decided in March of 1957 to have one of the corporations in the group merge with A. Hollander & Son, Inc. in such a way that the Philips companies would acquire control of Hollander. This merger was effected in July 1957. Hollander had a two-million-dollar-plus net operating loss…
2Cases cited9 opinions
- American Pipe & Steel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957
- Beckett v. CommissionerUnited States Tax Court · 1963
- Fawn Fashions, Inc. v. CommissionerUnited States Tax Court · 1963
- Hawaiian Trust Co. v. United StatesCourt of Appeals for the Ninth Circuit · 1961
- Swiss Colony, Inc. v. CommissionerUnited States Tax Court · 1969
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