Legal Opinion

Pepi, Inc. v. Commissioner

United States Tax Court

Decided August 25, 1969No. Docket No. 276-67Published

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

  1. American Pipe & Steel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957
  2. Beckett v. CommissionerUnited States Tax Court · 1963
  3. Fawn Fashions, Inc. v. CommissionerUnited States Tax Court · 1963
  4. Hawaiian Trust Co. v. United StatesCourt of Appeals for the Ninth Circuit · 1961
  5. Swiss Colony, Inc. v. CommissionerUnited States Tax Court · 1969

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