Legal Opinion

McDonald's of Zion, 432, Ill., Inc. v. Commissioner

United States Tax Court

Decided June 11, 1981No. Docket Nos. 8083-77 -- 8109-77Published

McDonald's Corp. (McDonald's) wanted to acquire several franchised restaurants owned primarily by three individuals, Garb, Stern, and Imerman (the Garb-Stern group). McDonald's refused to offer any consideration other than its common stock because of financial accounting reasons. Although the Garb-Stern group wanted a cash transaction, they eventually agreed to accept 361,235 shares of unregistered common stock.

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McDonald's Corp. (McDonald's) wanted to acquire several franchised restaurants owned primarily by three individuals, Garb, Stern, and Imerman (the Garb-Stern group). McDonald's refused to offer any consideration other than its common stock because of financial accounting reasons. Although the Garb-Stern group wanted a cash transaction, they eventually agreed to accept 361,235 shares of unregistered common stock. The merger took place as of Apr. 1, 1973, whereupon McDonald's dropped down the acquired restaurants into wholly owned, operating subsidiaries (the petitioners herein). As part of the…

1Opinion of the Court

McDonald's of Zion, 432, Ill., Inc., et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

McDonald's of Zion, 432, Ill., Inc. v. Commissioner

Docket Nos. 8083-77 -- 8109-77

United States Tax Court

76 T.C. 972; 1981 U.S. Tax Ct. LEXIS 114;

June 11, 1981, Filed

Decisions will be entered under Rule 155.

McDonald's Corp. (McDonald's) wanted to acquire several franchised restaurants owned primarily by three individuals, Garb, Stern, and Imerman (the Garb-Stern group). McDonald's refused to offer any consideration other than its common stock because of financial accounting reasons.…

2Cases cited32 opinions

  1. Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
  2. Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
  3. LeTulle v. ScofieldSupreme Court of the United States · 1940
  4. Helvering v. Minnesota Tea Co.Supreme Court of the United States · 1935
  5. John A. Nelson Co. v. HelveringSupreme Court of the United States · 1935

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