Litton Business Systems, Inc. v. Commissioner
United States Tax Court
P corporation entered into an agreement with unrelated T corporation (an established financially successful business), whereby P, or a wholly owned subsidiary, would acquire all of the assets of T in exchange for voting common stock of P, pursuant to sec. 368(a)(1) (C), I.R.C. 1954. In order to effect the reorganization agreement, P incorporated a wholly owned subsidiary, S corporation.
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P corporation entered into an agreement with unrelated T corporation (an established financially successful business), whereby P, or a wholly owned subsidiary, would acquire all of the assets of T in exchange for voting common stock of P, pursuant to sec. 368(a)(1) (C), I.R.C. 1954. In order to effect the reorganization agreement, P incorporated a wholly owned subsidiary, S corporation. P stock, valued at $ 28,542,802.50, was then made available by P to S pursuant to a contribution to capital by P to S of $ 9,227,385.19 of P stock and by a sale of the remaining $ 19,315,417.31 of P stock by P…
1Opinion of the Court
Litton Business Systems, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Litton Business Systems, Inc. v. Commissioner
Docket No. 1085-68
United States Tax Court
61 T.C. 367; 1973 U.S. Tax Ct. LEXIS 3; 61 T.C. No. 42;
December 26, 1973, Filed
Decision will be entered under Rule 50.
P corporation entered into an agreement with unrelated T corporation (an established financially successful business), whereby P, or a wholly owned subsidiary, would acquire all of the assets of T in exchange for voting common stock of P, pursuant to sec. 368(a)(1) (C), I.R.C. 1954. In order to effect the…
2Cases cited24 opinions
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Fin Hay Realty Co. v. United StatesCourt of Appeals for the Third Circuit · 1968
- Gooding Amusement Co. v. CommissionerUnited States Tax Court · 1954
- John v. Rowan v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Litton Business Systems, Inc. v. CommissionerUnited States Tax Court · 1973
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