Tribune Co. v. Comm'r
United States Tax Court
In 1998, Times Mirror's investment subsidiary, TMD, divested itself of a legal publishing business through the Bender transaction. The transaction was intended and designed to qualify as a tax-free reorganization under sec. 368, I.R.C. R determined that the transaction was a taxable sale by TMD to Reed. Held: The primary consideration received in the transaction was control over $ 1.375 billion paid by Reed.
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In 1998, Times Mirror's investment subsidiary, TMD, divested itself of a legal publishing business through the Bender transaction. The transaction was intended and designed to qualify as a tax-free reorganization under sec. 368, I.R.C. R determined that the transaction was a taxable sale by TMD to Reed. Held: The primary consideration received in the transaction was control over $ 1.375 billion paid by Reed. Held, further, the Bender transaction did not qualify as a tax-free reorganization because the terms and provisions of the contractual documents, as interpreted and implemented by Times…
1Opinion of the Court
TRIBUNE COMPANY, AS AGENT OF AND SUCCESSOR BY MERGER TO THE FORMER THE TIMES MIRROR COMPANY, ITSELF AND ITS CONSOLIDATED SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Tribune Co. v. Comm'r
No. 17443-02
United States Tax Court
125 T.C. 110; 2005 U.S. Tax Ct. LEXIS 28; 125 T.C. No. 8;
September 27, 2005, Filed
In 1998, Times Mirror's investment subsidiary, TMD, divested
itself of a legal publishing business through the Bender
transaction. The transaction was intended and designed to
qualify as a tax-free reorganization under sec. 368, I.R.C. R
determined that the transaction…
2Cases cited16 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Minnesota Tea Co. v. HelveringSupreme Court of the United States · 1938
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