Pilgrim's Pride Corporation Successor in Interest to Pilgrim's Pride Corporation of Georgia f/k/a Gold Kist, Inc. v. Commissioner

141 T.C. No. 17

UNITED STATES TAX COURT PILGRIM’S PRIDE CORPORATION SUCCESSOR IN INTEREST TO PILGRIM’S PRIDE CORPORATION OF GEORGIA f.k.a. GOLD KIST, INC. SUCCESSOR IN INTEREST TO GOLD KIST INC. AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12089-10. Filed December 11, 2013. P is the successor in interest to G. G was contractually obligated to purchase, and in 1999 did purchase, securities from S and T for $98.6 million. The securities were capital assets of G. In 2004 S offered to redeem the securities for $20 million. G’s board of directors decided…