Legal Opinion
Textron Inc. v. Commissioner of IRS
Court of Appeals for the First Circuit
Decided July 16, 2003No. 02-2455PublishedCited by 32 opinions
1Opinion of the Court
JOHN C. PORFILIO, Senior Circuit Judge.
Textron Inc. and Subsidiary Companies (Textron) appeals an order in the Tax Court holding its subsidiary, Paul Revere Corporation (Paul Revere), was not permitted to deduct its $14,934,745 capital loss in Textron’s 1987 taxable year. We reverse.
Textron is the common parent of an affiliated group of corporations within the meaning of I.R.C. § 1504(a). The general rule of I.R.C. § 1001 requires consolidated groups to recognize gain or loss upon an exchange of property. However, if three listed conditions are met, Treas. Reg. § 1.1502 — 14(d) (4) (i)…
2Cases cited13 opinions
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Estate of Cowart v. Nicklos Drilling Co.Supreme Court of the United States · 1992
- Woodral v. CommissionerUnited States Tax Court · 1999
- Commissioner v. SolimanSupreme Court of the United States · 1993
- Gitlitz v. CommissionerSupreme Court of the United States · 2001
8 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- In Re Pharm. Industry Average Wholesale Price Lit.Court of Appeals for the First Circuit · 2009
- Antilles Cement Corp. v. Cemex De Puerto Rico, Inc.Court of Appeals for the First Circuit · 2012
- United States v. LachmanCourt of Appeals for the First Circuit · 2004
- Gilbert v. Residential Funding LLCCourt of Appeals for the Fourth Circuit · 2012
- United States v. SavareseCourt of Appeals for the First Circuit · 2004
27 more not listed; retrieve them via the Exa API.