Legal Opinion

Exelon Corp. v. Comm'r

United States Tax Court

Decided September 19, 2016No. Docket Nos. 29183-13, 29184-13Published

P, a corporation engaged in the production, transmission, and distribution of electricity to residential, commercial, and industrial customers in Northern Illinois, sold its fossil fuel power plants in 1999 for $4.813 billion. Seeking to manage the taxable gain of $1.6 billion resulting from the sale, P pursued a series of like-kind exchanges employing sale-leaseback strategies between P and unrelated third parties C and M, each of the latter a tax-exempt public utility.

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P, a corporation engaged in the production, transmission, and distribution of electricity to residential, commercial, and industrial customers in Northern Illinois, sold its fossil fuel power plants in 1999 for $4.813 billion. Seeking to manage the taxable gain of $1.6 billion resulting from the sale, P pursued a series of like-kind exchanges employing sale-leaseback strategies between P and unrelated third parties C and M, each of the latter a tax-exempt public utility. P fully funded the transactions using the proceeds from the sale of its own power plants. In the transactions, C or M would…

1Opinion of the Court

EXELON CORPORATION, AS SUCCESSOR BY MERGER TO UNICOM CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent;

EXELON CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Exelon Corp. v. Comm'r

Docket Nos. 29183-13, 29184-13.

United States Tax Court

2016 U.S. Tax Ct. LEXIS 26; 147 T.C. No. 9;

September 19, 2016, Filed

P, a corporation engaged in the production, transmission, and distribution of electricity to residential, commercial, and industrial customers in Northern Illinois, sold its fossil fuel power plants in 1999 for $4.813…

2Cases cited43 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  3. United States v. BoyleSupreme Court of the United States · 1985
  4. Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
  5. United States v. CartwrightSupreme Court of the United States · 1973

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