Pilgrim's Pride Corp. v. Comm'r
United States Tax Court
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.
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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 to abandon the securities for no consideration because a $98.6 million ordinary loss would produce tax savings greater than the $20 million offered by S. On June 24, 2004, G voluntarily surrendered the securities to S and T for no consideration. On its Federal income tax return for the tax year ending June 30, 2004,…
1Opinion of the 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
Pilgrim's Pride Corp. v. Comm'r
Docket No. 12089-10.
United States Tax Court
141 T.C. 533; 2013 U.S. Tax Ct. LEXIS 37; 141 T.C. No. 17;
December 11, 2013, Filed
In re Pilgrim's Pride Corp., 2012 Bankr. LEXIS 447 (Bankr. N.D. Tex., Jan. 31, 2012)
Decision will be entered for respondent with respect to the deficiency and for petitioner with respect to the accuracy-related…
2Cases cited38 opinions
- Landgraf v. USI Film ProductsSupreme Court of the United States · 1994
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Griffin v. Oceanic Contractors, Inc.Supreme Court of the United States · 1982
- United States v. CraftSupreme Court of the United States · 2002
- Burnet v. WellsSupreme Court of the United States · 1933
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