Uniroyal, Inc. v. Commissioner
United States Tax Court
U and I, corporations, each held 50 percent of the stock of R. U and I deadlocked over R's future operations. After extensive negotiations, U and I agreed in general that (1) R would be split into two companies -- R (which would be owned solely by I) and R2 (which would be owned equally by U and I) -- and (2) U would receive a total of $ 31 million in cash. However, no binding agreement was entered into, and U and I continued to negotiate.
Read the full summary
U and I, corporations, each held 50 percent of the stock of R. U and I deadlocked over R's future operations. After extensive negotiations, U and I agreed in general that (1) R would be split into two companies -- R (which would be owned solely by I) and R2 (which would be owned equally by U and I) -- and (2) U would receive a total of $ 31 million in cash. However, no binding agreement was entered into, and U and I continued to negotiate. On or about Dec. 28, 1981, R created R2 as its wholly owned subsidiary. On Dec. 31, 1981, R transferred $ 16.5 million in cash to U and a $ 16.5 million…
1Opinion of the Court
UNIROYAL INCORPORATED AND CONSOLIDATED SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Uniroyal, Inc. v. Commissioner
Docket No. 46733-86
United States Tax Court
T.C. Memo 1993-214; 1993 Tax Ct. Memo LEXIS 207; 65 T.C.M. (CCH) 2690;
May 18, 1993, Filed
U and I, corporations, each held 50 percent of the stock of R. U and I deadlocked over R's future operations. After extensive negotiations, U and I agreed in general that (1) R would be split into two companies -- R (which would be owned solely by I) and R2 (which would be owned equally by U and I) -- and (2) U would receive…
2Cases cited34 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Pullman-Standard v. SwintSupreme Court of the United States · 1982
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- United States v. IshamSupreme Court of the United States · 1873
29 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Richard Hansen Land, Inc. v. CommissionerUnited States Tax Court · 1993
- Rollins v. CommissionerUnited States Tax Court · 1993