Legal Opinion
Capital Blue Cross and Subsidiaries v. Commissioner
United States Tax Court
Decided March 12, 2004No. 13322-01Unknown
1Opinion of the Court
122 T.C. No. 11
UNITED STATES TAX COURT CAPITAL BLUE CROSS AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13322-01. Filed March 12, 2004. As part of its statutory conversion under sec. 1012(a) and (b) of the Tax Reform Act of 1986,
Pub. L. 99-514, 100
Stat. 2390, from a tax-exempt to a taxable entity, petitioner generally was entitled to step up its tax basis in its assets to their Jan. 1, 1987, fair market value. Held, among other things, for 1994: (1) The basis step-up provision of sec. 1012(c)(3)(A)(ii) of the Tax Reform Act of 1986,
Pub. L. 99-514, 100
S…
2Cases cited36 opinions
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Robinson v. Shell Oil Co.Supreme Court of the United States · 1997
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- Green v. Bock Laundry MacHine Co.Supreme Court of the United States · 1989
- Idahoan Fresh v. Advantage ProduceCourt of Appeals for the Third Circuit · 1998
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