ISC Industries, Inc. v. Commissioner
United States Tax Court
Petitioner's principal business was the consumer finance business. Using funds borrowed for use in the finance business petitioner purchased 53 percent of the outstanding stock of Lincoln Bakery with the intention that the bakery be merged into petitioner. On the day that the merger was consummated, petitioner mortaged assets of the bakery and transferred them to a wholly owned subsidiary. Petitioner retained the mortgage proceeds for use in its finance business.
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Petitioner's principal business was the consumer finance business. Using funds borrowed for use in the finance business petitioner purchased 53 percent of the outstanding stock of Lincoln Bakery with the intention that the bakery be merged into petitioner. On the day that the merger was consummated, petitioner mortaged assets of the bakery and transferred them to a wholly owned subsidiary. Petitioner retained the mortgage proceeds for use in its finance business. Petitioner's principal purpose in causing the subsidiary to assume the mortgage was to protect its finance business from a…
1Opinion of the Court
ISC Industries Inc., Successor of Indian Finance Corporation v. Commissioner.
ISC Industries, Inc. v. Commissioner
Docket No. 4060-69.
United States Tax Court
T.C. Memo 1971-283; 1971 Tax Ct. Memo LEXIS 50; 30 T.C.M. (CCH) 1216; T.C.M. (RIA) 71283;
November 3, 1971, Filed.
Petitioner's principal business was the consumer finance business. Using funds borrowed for use in the finance business petitioner purchased 53 percent of the outstanding stock of Lincoln Bakery with the intention that the bakery be merged into petitioner. On the day that the merger was consummated, petitioner mortaged assets of…
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- Drybrough v. CommissionerUnited States Tax Court · 1964
- F. W. Drybrough v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1967
- Ellis Campbell, Jr., District Director of Internal Revenue v. Clifford W. Wheeler and Lillian v. Wheeler, AppellesCourt of Appeals for the Fifth Circuit · 1965
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