Interlake Corp. v. Commissioner
United States Tax Court
P, as the result of a restructuring transaction, became the successor common parent of a consolidated group of corporations (the group). A, the former common parent of the group, became a wholly owned subsidiary of P. P then distributed, pro rata, to its shareholders, all of the issued and outstanding common shares of A, which became, as a result of the spinoff, a separate publicly traded corporation.
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P, as the result of a restructuring transaction, became the successor common parent of a consolidated group of corporations (the group). A, the former common parent of the group, became a wholly owned subsidiary of P. P then distributed, pro rata, to its shareholders, all of the issued and outstanding common shares of A, which became, as a result of the spinoff, a separate publicly traded corporation. Subsequent to the restructuring transaction, P and the group incurred a consolidated net operating loss (CNOL). P filed an application under sec. 6411, I.R.C., for a tentative refund of income…
1Opinion of the Court
INTERLAKE CORPORATION, SUCCESSOR IN INTEREST TO INTERLAKE, INC., AND CONSOLIDATED SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Interlake Corp. v. Commissioner
No. 8258-96
United States Tax Court
112 T.C. 103; 1999 U.S. Tax Ct. LEXIS 10; 112 T.C. No. 10;
March 18, 1999, Filed
An appropriate order and decision will be entered.
P, as the result of a restructuring transaction, became the
successor common parent of a consolidated group of corporations
(the group). A, the former common parent of the group, became a
wholly owned subsidiary of P. P then distributed, pro rata, to
its…
2Cases cited9 opinions
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Raymond E. And Dorothy J. O'Bryant v. United StatesCourt of Appeals for the Seventh Circuit · 1995
- Midland Mortg. Co. v. CommissionerUnited States Tax Court · 1980
- Groetzinger v. CommissionerUnited States Tax Court · 1977
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