Textron Inc. v. Comm'r
United States Tax Court
P, a domestic corporation, acquired substantially all of the stock of A, a foreign corporation. The Federal Trade Commission (FTC) contemporaneously filed a complaint in U.S. District Court seeking to enjoin P's acquisition and control of A pending resolution of potential restraint of trade issues. Pursuant to the court's order, P transferred its A stock to a voting trust pending the FTC's consideration of the issues.
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P, a domestic corporation, acquired substantially all of the stock of A, a foreign corporation. The Federal Trade Commission (FTC) contemporaneously filed a complaint in U.S. District Court seeking to enjoin P's acquisition and control of A pending resolution of potential restraint of trade issues. Pursuant to the court's order, P transferred its A stock to a voting trust pending the FTC's consideration of the issues. The trust had an independent trustee who held and voted the stock without influence by P. The trustee was directed to, and did, operate A independently of P and as an active…
1Opinion of the Court
OPINION
Laro, Judge:
This matter is before the Court on cross-motions for partial summary judgment. See Rule 121.1 Petitioner petitioned the Court to redetermine respondent’s determination of deficiencies of $5,083,201, $1,783,938, $244,211, $1,152,171, $14,011,513, and $68,811 in its Federal income tax for its taxable years ended January 2, 1988, December 31, 1988, December 30, 1989, December 29, 1990, December 28, 1991, and January 2, 1993, respectively.
Following our disposition of the other issue in this case, see Textron Inc. & Sub. Cos. v. Commissioner, 115 T.C. 104 (2000), we must decide…
2Cases cited11 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- National Railroad Passenger Corporation v. National Assn. of Railroad PassengersSupreme Court of the United States · 1974
- Naftel v. CommissionerUnited States Tax Court · 1985
- Bond v. CommissionerUnited States Tax Court · 1993
- Estate of O'Connor v. CommissionerUnited States Tax Court · 1977
6 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Dow Chemical Co. and Subsidiaries v. United StatesDistrict Court, E.D. Michigan · 2003
- United States v. Textron Inc. and SubsidiariesDistrict Court, D. Rhode Island · 2007
- Eaton Corporation and Subsidiaries v. CommissionerUnited States Tax Court · 2019
- Textron Inc. and Subsidiary Companies v. CommissionerUnited States Tax Court · 2001
- Textron Inc. v. Comm'rUnited States Tax Court · 2001
1 more not listed; retrieve them via the Exa API.