Carpenter Technology Corp. v. Commissioner of Revenue Services

HON. ARNOLD W. ARONSON, JUDGE TRIAL REFEREE.

For the tax years ending June 30,1990, and June 30, 1991, the defendant, the commissioner of revenue services (commissioner), disallowed an interest deduction on loans made from a wholly owned subsidiary, Carpenter Investments, Inc. (Investments), to the plaintiff, Carpenter Technology Corporation (Carpenter), on the basis that Investments was a sham and the transactions at issue between Carpenter and Investments had no economic substance. Carpenter appeals pursuant to General Statutes § 12-237 the commissioner’s deficiency assessment of corporation…