Legal Opinion

Trinova Corp. v. Commissioner

United States Tax Court

Decided February 27, 1997No. Docket No. 2931-94Published

P, a corporation, filed a consolidated tax return with its affiliated companies. P operated a division with assets that included certain section 38 assets upon which investment tax credits (ITC) had been claimed.

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P, a corporation, filed a consolidated tax return with its affiliated companies. P operated a division with assets that included certain section 38 assets upon which investment tax credits (ITC) had been claimed. P transferred the division assets to a wholly owned subsidiary, G. P agreed to transfer its shares in G to another shareholder, H, in return for H's shares in P. The two transactions qualified for nonrecognition status under secs. 351, 355, and 368 (a) (1) (D), I.R.C. R determined a deficiency for P's failure to include ITC recapture in income under sec. 47(a), I.R.C., on its 1986…

1Opinion of the Court

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

Trinova Corp. v. Commissioner

Docket No. 2931-94

United States Tax Court

108 T.C. 68; 1997 U.S. Tax Ct. LEXIS 6; 108 T.C. No. 6;

February 27, 1997, Filed

P, a corporation, filed a consolidated tax return with its affiliated companies. P operated a division with assets that included certain section 38 assets upon which investment tax credits (ITC) had been claimed. P transferred the division assets to a wholly owned subsidiary, G. P agreed to transfer its shares in G to another shareholder, H, in return…

Also in this document: Dissent.

2Cases cited28 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. Commissioner v. WilcoxSupreme Court of the United States · 1946
  4. James E. Threlkeld v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1988
  5. Threlkeld v. CommissionerUnited States Tax Court · 1986

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