Southern Pacific Co. v. Commissioner
United States Tax Court
Old SP was the common parent of an affiliated group that filed consolidated income tax returns for the years at issue, calendar years 1962 through 1965. During 1969, but prior to Nov. 26, 1969, new SP and its wholly owned subsidiary, SPTC, were formed. On Nov. 26, 1969, a merger occurred in which (1) SPTC received all the assets of old SP, (2) the shareholders of old SP became the shareholders of new SP, (3) old SP was dissolved, and (4) new SP assumed the name of old SP.
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Old SP was the common parent of an affiliated group that filed consolidated income tax returns for the years at issue, calendar years 1962 through 1965. During 1969, but prior to Nov. 26, 1969, new SP and its wholly owned subsidiary, SPTC, were formed. On Nov. 26, 1969, a merger occurred in which (1) SPTC received all the assets of old SP, (2) the shareholders of old SP became the shareholders of new SP, (3) old SP was dissolved, and (4) new SP assumed the name of old SP. Respondent was notified on Dec. 2, 1969, of the dissolution of old SP and that SPTC had been designated as successor agent…
1Opinion of the Court
Southern Pacific Company (formerly S. P. Inc.), Petitioner v. Commissioner of Internal Revenue, Respondent
Southern Pacific Co. v. Commissioner
Docket No. 7502-72
United States Tax Court
84 T.C. 375; 1985 U.S. Tax Ct. LEXIS 109; 84 T.C. No. 28;
March 12, 1985. March 12, 1985, Filed
Petitioners' motion to dismiss for lack of jurisdiction will be denied.
Old SP was the common parent of an affiliated group that filed consolidated income tax returns for the years at issue, calendar years 1962 through 1965. During 1969, but prior to Nov. 26, 1969, new SP and its wholly owned subsidiary, SPTC, were…
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