United States v. Federated Department Stores, Inc. (In Re Federated Department Stores, Inc.)

OPINION AND ORDER

GEORGE C. SMITH, District Judge.

The government appeals the bankruptcy court’s decision allowing Federated Department Stores, Inc. (“Federated”) to deduct certain tax attributes. 1 This action arises out of Federated’s acquisition of Twin Fair Distributors Corporation’s (“TFDC”) stock in May 1982. Following this stock purchase, the seven TFDC stores Federated acquired were operated as Gold Circle stores, a retailing division of Federated. TFDC operated as a separate subsidiary of Federated. In April 1985, Federated liquidated and dissolved TFDC. Consequently, Federated…