Legal Opinion
Tennessee-Carolina Transportation, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided August 21, 1978No. 76-2496PublishedCited by 31 opinions
1Opinion of the Court
CELEBREZZE, Circuit Judge.
The principal issue presented on appeal is whether the tax benefit rule1 is applicable to a corporate liquidation governed by Internal Revenue Code § 336. We hold that it is and affirm the decision of the Tax Court.2
Taxpayer, Tennessee-Carolina Transportation, Inc., is a Tennessee corporation engaged in the motor freight transportation business. Pursuant to a contract entered into in 1966, taxpayer purchased in January, 1967, all of the capital stock of Service Lines, Inc. (Service). Service was also engaged in the motor freight transportation business. Service was…
2Cases cited14 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Alice Phelan Sullivan Corporation, a California Corporation v. The United StatesUnited States Court of Claims · 1967
- Central Tablet Manufacturing Co. v. United StatesSupreme Court of the United States · 1974
- Nash v. United StatesSupreme Court of the United States · 1970
9 more not listed; retrieve them via the Exa API.
3Cited by31 opinions
- Hillsboro National Bank v. CommissionerSupreme Court of the United States · 1983
- Estate of Delman v. CommissionerUnited States Tax Court · 1979
- Davis v. CommissionerUnited States Tax Court · 1980
- 885 Inv. Co. v. CommissionerUnited States Tax Court · 1990
- Bonaire Development Co. v. CommissionerUnited States Tax Court · 1981
26 more not listed; retrieve them via the Exa API.