Legal Opinion

Henry C. Beck Builders, Inc. v. Commissioner

United States Tax Court

Decided February 18, 1964No. Docket Nos. 90101, 90102, 90108, 90109Published

A parent corporation's intercompany profit, properly eliminated from a consolidated return in 1953, held not to constitute income to the parent in 1957, when the parent sold all the subsidiary's stock to an unrelated party.

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A parent corporation's intercompany profit, properly eliminated from a consolidated return in 1953, held not to constitute income to the parent in 1957, when the parent sold all the subsidiary's stock to an unrelated party. On redemption of the subsidiary's preferred stock, the parent's basis is reduced by the subsidiary's losses sustained during taxable years prior to the redemption, but only to the extent such losses were availed of by the parent (there being no other subsidiaries here) during the taxable years prior to the redemption and could not have been availed of by the subsidiary…

1Opinion of the Court

Henry C. Beck Builders, Inc., et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent

Henry C. Beck Builders, Inc. v. Commissioner

Docket Nos. 90101, 90102, 90108, 90109

United States Tax Court

41 T.C. 616; 1964 U.S. Tax Ct. LEXIS 150;

February 18, 1964, Filed

Decisions will be entered under Rule 50.

A parent corporation's intercompany profit, properly eliminated from a consolidated return in 1953, held not to constitute income to the parent in 1957, when the parent sold all the subsidiary's stock to an unrelated party. On redemption of the subsidiary's preferred stock, the parent's…

Also in this document: Concurrence; Dissent.

2Cases cited40 opinions

  1. United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
  2. Hanover Bank v. CommissionerSupreme Court of the United States · 1962
  3. Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
  4. Commissioner v. BilderSupreme Court of the United States · 1962
  5. Burnet v. Aluminum Goods Manufacturing Co.Supreme Court of the United States · 1933

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