Argus, Inc. v. Commissioner
United States Tax Court
Held, where subsidiary corporation is merged into its parent in a transaction to which section 334(b)(2), I.R.C. 1954, is applicable, balance in reserve for bad debts of subsidiary constitutes income to subsidiary for its final taxable year.
1Opinion of the Court
OPINION
Scott, Judge:
Respondent determined that petitioner was liable as transferee for a deficiency plus interest as provided by law in the income tax of Mansfield Industries, Inc. (Illinois) (hereinafter referred to as Mansfield-Illinois), for its taxable year July 1, 1960, to September 1, 1960, the amount of the deficiency so determined being $15,719.38. Petitioner concedes it is liable for any deficiency in tax plus statutory interest owed by Mansfield-Illinois but contests the correctness of respondent’s determination of such deficiency, leaving for our decision the following issue:
Whether…
2Cases cited10 opinions
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
- Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Geyer, Cornell & Newell, Inc. v. CommissionerUnited States Tax Court · 1946
- West Seattle National Bank of Seattle v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1961
- West Seattle Nat'l Bank v. CommissionerUnited States Tax Court · 1959
5 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Pacific Transport Co. v. CommissionerUnited States Tax Court · 1970
- Eastern Color Printing Co. v. CommissionerUnited States Tax Court · 1974
- Kansas Sand & Concrete, Inc. v. CommissionerUnited States Tax Court · 1971
- First Nat'l State Bank v. CommissionerUnited States Tax Court · 1968
- Moss American, Inc. v. CommissionerUnited States Tax Court · 1974
9 more not listed; retrieve them via the Exa API.