Fairfield Communities Land Co. v. Commissioner
United States Tax Court
Fairfield, a land development company, with few stockholders, sought to acquire the assets and liabilities of Oceans, an unrelated company that was in liquidation. Oceans had cash in the amount of about $575,000, few known liabilities, and its stock was publicly traded. It had a net operating loss carryover of $1,645,767; Fairfield had net operating loss carryovers of in excess of 2 million dollars.
Read the full summary
Fairfield, a land development company, with few stockholders, sought to acquire the assets and liabilities of Oceans, an unrelated company that was in liquidation. Oceans had cash in the amount of about $575,000, few known liabilities, and its stock was publicly traded. It had a net operating loss carryover of $1,645,767; Fairfield had net operating loss carryovers of in excess of 2 million dollars. In June 1971 an agreement was reached whereunder Greers Ferry, a wholly owned subsidiary of Fairfield with little or no income and few assets, acquired all the assets and liabilities of Oceans in…
1Opinion of the Court
FAIRFIELD COMMUNITIES LAND COMPANY AND AFFILIATED SUBSIDIARIES v. COMMISSIONER OF INTERNAL REVENUE
Fairfield Communities Land Co. v. Commissioner
Docket No. 6164-78.
United States Tax Court
T.C. Memo 1984-100; 1984 Tax Ct. Memo LEXIS 571; 47 T.C.M. (CCH) 1194; T.C.M. (RIA) 84100;
March 1, 1984.
Fairfield, a land development company, with few stockholders, sought to acquire the assets and liabilities of Oceans, an unrelated company that was in liquidation. Oceans had cash in the amount of about $575,000, few known liabilities, and its stock was publicly traded. It had a net operating loss carryover…
2Cases cited10 opinions
- VGS Corp. v. CommissionerUnited States Tax Court · 1977
- H. F. Ramsey Co. v. CommissionerUnited States Tax Court · 1965
- D'Arcy-MacManus & Masius, Inc. v. CommissionerUnited States Tax Court · 1975
- Hawaiian Trust Co. v. United StatesCourt of Appeals for the Ninth Circuit · 1961
- Capri, Inc. v. CommissionerUnited States Tax Court · 1975
5 more not listed; retrieve them via the Exa API.