Federal Bulk Carriers, Inc. v. Commissioner
United States Tax Court
F corp. (the taxpayer) and B corp. owned 100 percent of the outstanding securities in X corp., which they sold in 1961 to M corp. under a complicated arrangement (restructured in 1963) which in effect guaranteed a specified projected level of earnings of the only asset of substance (a tanker) indirectly owned by X through a wholly owned subsidiary of X. The earnings of the tanker failed to reach the projected level, and upon final termination of the arrangement in 1965 and…
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F corp. (the taxpayer) and B corp. owned 100 percent of the outstanding securities in X corp., which they sold in 1961 to M corp. under a complicated arrangement (restructured in 1963) which in effect guaranteed a specified projected level of earnings of the only asset of substance (a tanker) indirectly owned by X through a wholly owned subsidiary of X. The earnings of the tanker failed to reach the projected level, and upon final termination of the arrangement in 1965 and 1966, F sustained losses based upon its share of the amount by which the actual earnings of the tanker fell short of the…
1Opinion of the Court
Federal Bulk Carriers, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Federal Bulk Carriers, Inc. v. Commissioner
Docket No. 6115-73
United States Tax Court
66 T.C. 283; 1976 U.S. Tax Ct. LEXIS 108;
May 18, 1976, Filed
Decision will be entered for the respondent.
F corp. (the taxpayer) and B corp. owned 100 percent of the outstanding securities in X corp., which they sold in 1961 to M corp. under a complicated arrangement (restructured in 1963) which in effect guaranteed a specified projected level of earnings of the only asset of substance (a tanker) indirectly owned by X through…
2Cases cited15 opinions
- United States v. GilmoreSupreme Court of the United States · 1963
- Woodward v. CommissionerSupreme Court of the United States · 1970
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- Luna v. CommissionerUnited States Tax Court · 1964
- Beck Chemical Equipment Corp. v. CommissionerUnited States Tax Court · 1957
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