Aeroquip-Vickers, Inc. And Subsidiaries, F/k/a Trinova Corp. And Subsidiaries v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
1Opinion of the Court
OPINION
GIBBONS, Circuit Judge.
In 1986, petitioner-appellee Aeroquip-Vickers, Inc. (formerly known as Trinova Corporation, and operating as the Libbey-*175Owens-Ford Company (LOF) at the time), transferred all of its assets relating to a glass manufacturing business, including property for which it had previously claimed investment tax credits (ITCs) under former 26 U.S.C. § 38 (Section 38 property), into a wholly-owned subsidiary, LOF Glass, Inc. (LOF Glass). LOF then transferred LOF Glass to one of its shareholders, Pilkington Holdings, in return for Pilkington Holdings’ shares in LOF. LOF…
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