Superior Coach of Florida, Inc. v. Commissioner
United States Tax Court
In 1974, Z, a majority shareholder and officer of P, purchased all of the shares of T Corp. and merged T into P. P wrote down the amount of ending inventory for such year. On audit, the Commissioner determined that the writedown was improper and revalued the amount of such ending inventory.
Read the full summary
In 1974, Z, a majority shareholder and officer of P, purchased all of the shares of T Corp. and merged T into P. P wrote down the amount of ending inventory for such year. On audit, the Commissioner determined that the writedown was improper and revalued the amount of such ending inventory. Held, P may not utilize T's net operating loss since the transaction did not qualify as a reorganization within the meaning of sec. 368(a)(1), I.R.C. 1954. Held, further, the Commissioner's revaluation of P's ending inventory constituted a change in P's method of accounting, requiring an adjustment under…
1Opinion of the Court
Superior Coach of Florida, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Superior Coach of Florida, Inc. v. Commissioner
Docket No. 9833-78
United States Tax Court
80 T.C. 895; 1983 U.S. Tax Ct. LEXIS 82; 80 T.C. No. 48;
May 16, 1983, Filed
Decision will be entered under Rule 155.
In 1974, Z, a majority shareholder and officer of P, purchased all of the shares of T Corp. and merged T into P. P wrote down the amount of ending inventory for such year. On audit, the Commissioner determined that the writedown was improper and revalued the amount of such ending inventory. Held, P may…
2Cases cited31 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. CliffordSupreme Court of the United States · 1940
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
26 more not listed; retrieve them via the Exa API.