Legal Opinion
Edward J. And Janice W. Caamano v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided August 7, 1989No. 88-4794PublishedCited by 4 opinions
1Opinion of the Court
GEE, Circuit Judge:
Facts
Taxpayers Edward and Janice Caamano, the appellees, were shareholders of McDer-mott, Inc. McDermott was a Delaware corporation and the parent of McDermott International, its Panamanian, wholly-owned subsidiary. The Board of Directors decided to change the corporate structure to make McDermott, Inc. the subsidiary of McDermott International. The Tax Court stated the motivation for the change was to reduce corporate taxes.
To make the structural change, McDer-mott International gave 30 million shares of its own common stock and 35 cents per share to the shareholders of…
2Cases cited3 opinions
- Commissioner of Internal Revenue v. Trustees Common Stock John Wanamaker PhiladelphiaCourt of Appeals for the Third Circuit · 1949
- United States v. R. Perry Collins, (Two Cases)Court of Appeals for the First Circuit · 1962
- Dunn Trust v. CommissionerUnited States Tax Court · 1986
3Cited by4 opinions
- Rohinton K. Bhada, Patricia A. Bhada v. Commissioner, Internal Revenue ServiceCourt of Appeals for the Sixth Circuit · 1989
- Combrink v. Comm'rUnited States Tax Court · 2001
- Combrink v. Comm'rUnited States Tax Court · 2001
- Gary D. and Lindy H. Combrink v. CommissionerUnited States Tax Court · 2001