Tenn. Natural Gas Lines v. Comm'r
United States Tax Court
Tennessee Natural Gas Lines, Inc.'s subsidiary, Nashville Gas Co., built a new liquefied natural gas facility, but transferred it to Tennessee Natural for operation in order to avoid subjecting Nashville Gas to Federal Power Commission regulation.
Read the full summary
Tennessee Natural Gas Lines, Inc.'s subsidiary, Nashville Gas Co., built a new liquefied natural gas facility, but transferred it to Tennessee Natural for operation in order to avoid subjecting Nashville Gas to Federal Power Commission regulation. Held, on the facts, the transfer (which triggered Nashville Gas' restoration of deferred gain) under sec. 1.1502-13(d), Income Tax Regs., occurred for tax purposes in 1973, when the burdens and benefits of ownership passed to Tennessee Natural, and not in 1974, when legal title was conveyed. Held, further, Tennessee Natural and not Nashville Gas…
1Opinion of the Court
Hall, Judge:
Respondent determined the following deficiencies in petitioners’ income tax:
Year Deficiency
1970 .$8,048
1971 . 77,620
Year Deficiency
1972.$54,580
1978 . 382,845
Petitioner Tennessee Natural Gas Lines, Inc. (Tennessee Natural), files its corporate income tax returns on a consolidated basis with its wholly owned subsidiary, petitioner Nashville Gas Co. (Nashville Gas). Due to concessions by both parties, the issues remaining for decision are:(1) Whether Nashville Gas must restore deferred gain on its sale to Tennessee Natural of a liquefied natural gas (LNG) facility in 1973 or 1974;…
2Cases cited10 opinions
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- International Business MacHines Corporation v. The United StatesUnited States Court of Claims · 1965
- Merrill v. CommissionerUnited States Tax Court · 1963
- Commissioner of Internal Revenue v. SegallCourt of Appeals for the Sixth Circuit · 1940
- Margaret v. Dettmers, Estate of Herrick L. Johnston, Deceased, and Margaret v. Dettmers, Individually v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1970
5 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Walter v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1985
- PPL Corp. & Subsidiaries v. CommissionerUnited States Tax Court · 2010
- Illinois Cereal Mills, Inc. v. CommissionerUnited States Tax Court · 1983
- Calvin v. CommissionerCourt of Appeals for the Sixth Circuit · 1985
- Major Realty Corp. v. CommissionerUnited States Tax Court · 1981
6 more not listed; retrieve them via the Exa API.