Cincinnati Transit, Inc. v. Commissioner of Internal Revenue

The Cincinnati Transit Company filed a timely petition for redetermination of a deficiency proposed by the Commissioner, and it was joined in the petition by Cincinnati Transit, Inc. Cincinnati Transit, Inc. was formed as a wholly-owned subsidiary of Cincinnati Transit Company, and both currently have assets and are doing business in Ohio. Pursuant to an agreement required by a Cincinnati ordinance, all obligations and liabilities of the Transit Company were assumed by Transit, Inc., and it is conceded that the latter will be required to pay whatever deficiency in federal tax liability may be…