Legal Opinion
Merrill Lynch & Co., Inc. & Subsidiaries v. Commissioner
United States Tax Court
Decided December 30, 2008No. 18170-98Unknown
1Opinion of the Court
131 T.C. No. 19
UNITED STATES TAX COURT MERRILL LYNCH & CO., INC. & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 18170-98. Filed December 30, 2008. MP decided to sell its wholly owned subsidiary, MLCR but wanted to retain a portion of MLCR’s assets within MP’s affiliated group. Before its sale, MLCR sold the stock in certain of its subsidiaries (issuing corporations) to brother-sister corporations in MP’s affiliated group (acquiring corporations). We held that these cross-chain sales, along with the subsequent sale of MLCR outside the affiliated group,…
2Cases cited8 opinions
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- Van Raden v. CommissionerUnited States Tax Court · 1979
- Commissioner of Internal Revenue v. Kenneth H., Susan L., Fred F., and Corinne B. Van RadenCourt of Appeals for the Ninth Circuit · 1981
- Merrill Lynch & Co., Inc., and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2004
- Fed. Home Loan Mortg. Corp. v. Comm'rUnited States Tax Court · 2003
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