Pabst Brewing Co. v. Commissioner
United States Tax Court
Pursuant to an agreement between P and H, H acquired a majority of P's shares in a public tender offer. P then distributed certain assets to H in exchange for the P shares acquired by H and the assumption by H of certain liabilities.
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Pursuant to an agreement between P and H, H acquired a majority of P's shares in a public tender offer. P then distributed certain assets to H in exchange for the P shares acquired by H and the assumption by H of certain liabilities. In cross-motions for partial summary judgment, R asserts that the transaction constitutes a redemption under sec. 311(d)(1), I.R.C. 1954, while P asserts that the transaction constitutes a sale under sec. 1001, I.R.C. 1954. P also objects to the admissibility of certain evidence submitted by R relating to the valuation of the distributed assets, and asserts that…
1Opinion of the Court
PABST BREWING COMPANY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Pabst Brewing Co. v. Commissioner
Docket No. 18466-92
United States Tax Court
T.C. Memo 1995-239; 1995 Tax Ct. Memo LEXIS 241; 69 T.C.M. (CCH) 2773;
June 1, 1995, Filed
Pursuant to an agreement between P and H, H acquired a majority of P's shares in a public tender offer. P then distributed certain assets to H in exchange for the P shares acquired by H and the assumption by H of certain liabilities. In cross-motions for partial summary judgment, R asserts that the transaction constitutes a redemption under sec.…
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- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
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