Wyman-Gordon Co. v. Commissioner
United States Tax Court
Petitioners are members of an affiliated group of corporations that filed consolidated Federal income tax returns. Wyman-Gordon, the parent corporation, canceled a debt owed to it by Woods & Copeland, a second-tier subsidiary, and Wyman-Gordon claimed a bad debt loss with respect thereto.
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Petitioners are members of an affiliated group of corporations that filed consolidated Federal income tax returns. Wyman-Gordon, the parent corporation, canceled a debt owed to it by Woods & Copeland, a second-tier subsidiary, and Wyman-Gordon claimed a bad debt loss with respect thereto. Due to its insolvency, Woods & Copeland did not include in taxable income the discharge of indebtedness income associated with the cancellation of its debt to Wyman-Gordon, but Woods & Copeland did increase its earnings and profits by the amount of the discharge of indebtedness income. As a result of the…
1Opinion of the Court
OPINION
SWIFT, Judge:
In a timely statutory notice of deficiency dated August 25, 1983, respondent determined deficiencies in the consolidated Federal income tax liabilities of petitioners Wyman-Gordon Co. and Rome Industries, Inc., members of an affiliated group of corporations, as follows:
Year Deficiency
1977 . $387,087
1978 . 1,019,439
1979 . 1,213,363
After concessions and resolution of till issues pertaining to 1977 and 1979, the sole issue for decision concerns the effect of discharge of indebtedness income on the computation of earnings and profits and on the computation of a taxpayer’s…
2Cases cited10 opinions
- Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
- Woods Inv. Co. v. CommissionerUnited States Tax Court · 1985
- Georgia-Pacific Corp. v. CommissionerUnited States Tax Court · 1975
- Meyer v. CommissionerUnited States Tax Court · 1966
- Lucile H. Meyer v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Leon R. MeyerCourt of Appeals for the Eighth Circuit · 1967
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