Acme Steel Co. v. Comm'r
United States Tax Court
P was the common parent of an affiliated group that was restructured in 1986. In 1986, pursuant to the restructuring plan, P formed a subsidiary, I. Following the formation of I, P became a subsidiary of I through an inversion.
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P was the common parent of an affiliated group that was restructured in 1986. In 1986, pursuant to the restructuring plan, P formed a subsidiary, I. Following the formation of I, P became a subsidiary of I through an inversion. I then distributed, pro rata to its shareholders in a spinoff, all the issued and outstanding common shares of P, which continued to hold all the shares of one pre-existing subsidiary of P. Following the restructuring and spinoff, P filed a consolidated Form 1120, U.S. Corporation Income Tax Return, for a 27-week 1986 tax year claiming a consolidated net operating loss…
1Opinion of the Court
ACME STEEL COMPANY (FORMERLY KNOWN AS INTERLAKE, INC., AND NOW KNOWN AS ACME METALS, INC.) AND CONSOLIDATED SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Acme Steel Co. v. Comm'r
No. 7885-94
United States Tax Court
T.C. Memo 2003-118; 2003 Tax Ct. Memo LEXIS 121; 85 T.C.M. (CCH) 1208;
April 28, 2003, Filed
Interlake Corp. v. Commissioner, 112 T.C. 103, 1999 U.S. Tax Ct. LEXIS 10 (1999)
Respondent's motion for entry of decision will be granted, and decision will be entered in accordance with the parties' stipulation of settled issues.
P was the common parent of an…
2Cases cited43 opinions
- Bender v. Williamsport Area School DistrictSupreme Court of the United States · 1986
- Willy v. Coastal Corp.Supreme Court of the United States · 1992
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Petzoldt v. CommissionerUnited States Tax Court · 1989
- United States v. International Building Co.Supreme Court of the United States · 1953
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- In re the Rehabilitation of Segregated Account of Ambac Assurance Corp.Wisconsin Supreme Court · 2012