Tennessee Carolina Transp., Inc. v. Commissioner
United States Tax Court
1. The fair market values of a terminal facility and of tires and tubes distributed to petitioner on the liquidation of a wholly owned subsidiary are determined. 2. S, a corporation, was engaged in the motor freight transportation business. It purchased tires and tubes for its own equipment and for equipment which it leased for use in its operations.
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1. The fair market values of a terminal facility and of tires and tubes distributed to petitioner on the liquidation of a wholly owned subsidiary are determined. 2. S, a corporation, was engaged in the motor freight transportation business. It purchased tires and tubes for its own equipment and for equipment which it leased for use in its operations. The cost of procuring tires and tubes to be mounted on equipment already in use was expensed when the tires and tubes were placed in service. The cost of tires and tubes purchased with new equipment was expensed at the time of the purchase. S was…
1Opinion of the Court
OPINION
Issue 1
The liquidation of Service was a complete liquidation of a subsidiary within the meaning of sections 332 and 334(b)(2).2 Therefore petitioner’s basis in the various assets which it received must be determined by allocating petitioner’s adjusted basis in its Service stock among them in proportion to .their relative fair market values on the date of distribution, March 1, 1967. Sec. 1.334-l(c)(4)(viii), Income Tax Regs.
For the purpose of applying section 1.334-l(c)(4)(viii), supra, petitioner valued the terminal at $150,000. Respondent determined that on the date it was…
2Cases cited22 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Alice Phelan Sullivan Corporation, a California Corporation v. The United StatesUnited States Court of Claims · 1967
- Mayfair Minerals, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1972
- Nash v. United StatesSupreme Court of the United States · 1970
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3Cited by36 opinions
- Putoma Corp. v. CommissionerUnited States Tax Court · 1976
- Estate of Delman v. CommissionerUnited States Tax Court · 1979
- Tennessee-Carolina Transportation, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1978
- Davis v. CommissionerUnited States Tax Court · 1980
- 885 Inv. Co. v. CommissionerUnited States Tax Court · 1990
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