Pioneer Parachute Co. v. Commissioner
United States Tax Court
Parent corporation owning 600 of 1,000 shares of common voting stock of a subsidiary desired to obtain the 95 percent ownership required for consolidated return purposes. Pursuant to plan, 398 shares of new class B preferred stock were issued by subsidiary and exchanged for 398 shares of its common stock held by two minority stockholders.
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Parent corporation owning 600 of 1,000 shares of common voting stock of a subsidiary desired to obtain the 95 percent ownership required for consolidated return purposes. Pursuant to plan, 398 shares of new class B preferred stock were issued by subsidiary and exchanged for 398 shares of its common stock held by two minority stockholders. Although the certificates for new stock stated that it was nonvoting, they provided that it could be converted into common stock, and that if a holder notified the secretary prior to any stockholders' meeting of his intention to convert, the meeting could…
1Opinion of the Court
Pioneer Parachute Company, Inc., v. Commissioner of Internal Revenue, Respondent
Pioneer Parachute Co. v. Commissioner
Docket No. 3367
United States Tax Court
6 T.C. 1246; 1946 U.S. Tax Ct. LEXIS 170;
May 31, 1946, Promulgated
Judgment will be entered for the respondent.
Parent corporation owning 600 of 1,000 shares of common voting stock of a subsidiary desired to obtain the 95 percent ownership required for consolidated return purposes. Pursuant to plan, 398 shares of new class B preferred stock were issued by subsidiary and exchanged for 398 shares of its common stock held by two minority…
2Cases cited5 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Higgins v. SmithSupreme Court of the United States · 1940
- Commissioner v. SmithSupreme Court of the United States · 1945
- Dow Chemical Co. v. Halliburton Oil Well Cementing Co.Supreme Court of the United States · 1945
- Pioneer Parachute Co. v. CommissionerUnited States Tax Court · 1946