Legal Opinion

Acro Mfg. Co. v. Commissioner

United States Tax Court

Decided November 8, 1962No. Docket No. 89281Published

Petitioner, whose principal business was the manufacture and sale of precision switches and thermostatic controls, acquired a subsidiary engaged in the manufacture of metal buttons for work clothing by acquiring all of its outstanding capital stock solely in exchange for shares of petitioner's own voting stock. Thereafter, pursuant to an agreement with a third party, petitioner caused the subsidiary to adopt a plan of complete liquidation which was consummated 1 day later.

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Petitioner, whose principal business was the manufacture and sale of precision switches and thermostatic controls, acquired a subsidiary engaged in the manufacture of metal buttons for work clothing by acquiring all of its outstanding capital stock solely in exchange for shares of petitioner's own voting stock. Thereafter, pursuant to an agreement with a third party, petitioner caused the subsidiary to adopt a plan of complete liquidation which was consummated 1 day later. Petitioner received as a liquidating distribution certain accounts receivable, inventories, land, and depreciable assets…

1Opinion of the Court

The Acro Manufacturing Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Acro Mfg. Co. v. Commissioner

Docket No. 89281

United States Tax Court

39 T.C. 377; 1962 U.S. Tax Ct. LEXIS 27;

November 8, 1962, Filed

Decision will be entered under Rule 50.

Petitioner, whose principal business was the manufacture and sale of precision switches and thermostatic controls, acquired a subsidiary engaged in the manufacture of metal buttons for work clothing by acquiring all of its outstanding capital stock solely in exchange for shares of petitioner's own voting stock. Thereafter, pursuant to…

2Cases cited3 opinions

  1. Rollingwood Corp. v. Commissioner of Internal Revenue. Bohannon v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1951
  2. Acro Mfg. Co. v. CommissionerUnited States Tax Court · 1962
  3. Advance Aluminum Castings Corp. v. HarrisonCourt of Appeals for the Seventh Circuit · 1946

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