Legal Opinion

Cincinnati Transit, Inc. v. Commissioner

United States Tax Court

Decided February 25, 1971No. Docket No. 904-70Published

In 1969 respondent mailed a notice of deficiency to The Cincinnati Transit Company determining deficiencies in its income taxes for the years 1956-64. In 1968 Transit Company caused to be organized Cincinnati Transit, Inc., a wholly owned subsidiary, and entered into an agreement with it transferring to Transit, Inc., certain assets and liabilities relating to the operation of a public transportation system in exchange for the stock of Transit, Inc. Thereafter Transit, Inc.,…

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In 1969 respondent mailed a notice of deficiency to The Cincinnati Transit Company determining deficiencies in its income taxes for the years 1956-64. In 1968 Transit Company caused to be organized Cincinnati Transit, Inc., a wholly owned subsidiary, and entered into an agreement with it transferring to Transit, Inc., certain assets and liabilities relating to the operation of a public transportation system in exchange for the stock of Transit, Inc. Thereafter Transit, Inc., operated the transportation system but Transit Company has assets and is currently doing business in the State of Ohio.…

1Opinion of the Court

Cincinnati Transit, Inc., Successor-in-Interest to The Cincinnati Transit Company (Now Known as American Controlled Industries, Inc.) and The Cincinnati Transit Company (Now Known as American Controlled Industries, Inc.), Petitioners v. Commissioner of Internal Revenue, Respondent

Cincinnati Transit, Inc. v. Commissioner

Docket No. 904-70

United States Tax Court

55 T.C. 879; 1971 U.S. Tax Ct. LEXIS 181;

February 25, 1971, Filed

In 1969 respondent mailed a notice of deficiency to The Cincinnati Transit Company determining deficiencies in its income taxes for the years 1956-64. In 1968 Transit…

2Cases cited14 opinions

  1. Helvering v. Morgan's, Inc.Supreme Court of the United States · 1934
  2. International Union, United Automobile, Aerospace & Agricultural Implement Workers, Local 283 v. ScofieldSupreme Court of the United States · 1965
  3. Krueger v. CommissionerUnited States Tax Court · 1967
  4. Thomas A. Daboul, and A. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1970
  5. Cincinnati Transit, Inc. v. CommissionerUnited States Tax Court · 1971

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