Kaiser Aluminum & Chemical Corp. v. Commissioner
United States Tax Court
Kaiser, Comalco, and CRA after extensive negotiations agreed that KAAC (Kaiser's subsidiary) would transfer a 4-percent interest in QAL, an Australian corporation, to Comalco, along with cash; CRA agreed to transfer a 12.5-percent interest in QAL to Comalco along with cash. Kaiser and CRA each own a 45-percent interest in Comalco, also an Australian corporation, and a major producer of bauxite.
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Kaiser, Comalco, and CRA after extensive negotiations agreed that KAAC (Kaiser's subsidiary) would transfer a 4-percent interest in QAL, an Australian corporation, to Comalco, along with cash; CRA agreed to transfer a 12.5-percent interest in QAL to Comalco along with cash. Kaiser and CRA each own a 45-percent interest in Comalco, also an Australian corporation, and a major producer of bauxite. Both Kaiser and Comalco are (along with their subsidiaries) integrated producers of aluminum and aluminum products. QAL processes bauxite into alumina for its owners in proportion to their ownership…
1Opinion of the Court
Kaiser Aluminum & Chemical Corporation and Kaiser Alumina Australia Corporation, Petitioners v. Commissioner of Internal Revenue, Respondent
Kaiser Aluminum & Chemical Corp. v. Commissioner
Docket No. 3162-78T
United States Tax Court
76 T.C. 325; 1981 U.S. Tax Ct. LEXIS 170;
February 18, 1981, Filed
Kaiser, Comalco, and CRA after extensive negotiations agreed that KAAC (Kaiser's subsidiary) would transfer a 4-percent interest in QAL, an Australian corporation, to Comalco, along with cash; CRA agreed to transfer a 12.5-percent interest in QAL to Comalco along with cash. Kaiser and CRA each own a…
2Cases cited2 opinions
- Dittler Bros., Inc. v. CommissionerUnited States Tax Court · 1979
- Kaiser Aluminum & Chemical Corp. v. CommissionerUnited States Tax Court · 1981