D'Arcy-MacManus & Masius, Inc. v. Commissioner
United States Tax Court
In 1967 WWB-Cal acquired all the assets of HSI, a corporation which had suffered net operating losses in several of its preceding taxable years. Held, the acquisition was not made for the principal purpose of evading or avoiding Federal income tax.
1Opinion of the Court
D'Arcy-MacManus & Masius, Inc. (as successor to MacManus, John and Adams, Inc.), Petitioner v. Commissioner of Internal Revenue, Respondent
D'Arcy-MacManus & Masius, Inc. v. Commissioner
Docket Nos. 8593-71, 8594-71
United States Tax Court
63 T.C. 440; 1975 U.S. Tax Ct. LEXIS 204;
January 2, 1975, Filed
Decisions will be entered for the petitioner.
In 1967 WWB-Cal acquired all the assets of HSI, a corporation which had suffered net operating losses in several of its preceding taxable years. Held, the acquisition was not made for the principal purpose of evading or avoiding Federal income tax.
Herrick…
2Cases cited11 opinions
- Commodores Point Terminal Corp. v. CommissionerUnited States Tax Court · 1948
- Baton Rouge Supply Co. v. CommissionerUnited States Tax Court · 1961
- Vulcan Materials Company v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- D'Arcy-MacManus & Masius, Inc. v. CommissionerUnited States Tax Court · 1975
- The Zanesville Investment Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1964
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