Textron Inc. and Subsidiary Companies v. Commissioner

117 T.C. No. 7

UNITED STATES TAX COURT TEXTRON INC. AND SUBSIDIARY COMPANIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20643-98. Filed August 21, 2001. P, a domestic corporation, acquired substantially all of the stock of A, a foreign corporation. The Federal Trade Commission (FTC) contemporaneously filed a complaint in U.S. District Court seeking to enjoin P’s acquisition and control of A pending resolution of potential restraint of trade issues. Pursuant to the court’s order, P transferred its A stock to a voting trust pending the FTC’s consideration of the…