Textron Inc. v. Comm'r
United States Tax Court
P, a domestic corporation, acquired substantially all of the stock of A, a foreign corporation. The Federal Trade Commission (FTC) contemporaneously filed a complaint in U.S. District Court seeking to enjoin P's acquisition and control of A pending resolution of potential restraint of trade issues. Pursuant to the court's order, P transferred its A stock to a voting trust pending the FTC's consideration of the issues.
Read the full summary
P, a domestic corporation, acquired substantially all of the stock of A, a foreign corporation. The Federal Trade Commission (FTC) contemporaneously filed a complaint in U.S. District Court seeking to enjoin P's acquisition and control of A pending resolution of potential restraint of trade issues. Pursuant to the court's order, P transferred its A stock to a voting trust pending the FTC's consideration of the issues. The trust had an independent trustee who held and voted the stock without influence by P. The trustee was directed to, and did, operate A independently of P and as an active…
1Opinion of the Court
TEXTRON INC. AND SUBSIDIARY COMPANIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Textron Inc. v. Comm'r
No. 20643-98
United States Tax Court
117 T.C. 67; 2001 U.S. Tax Ct. LEXIS 37; 117 T.C. No. 7;
August 21, 2001, Filed
Textron Inc. v. Commissioner, 115 T.C. 104, 2000 U.S. Tax Ct. LEXIS 49 (2000)
An order will be issued granting respondent's motion for partial summary judgment and denying petitioner's motion for partial summary judgment, and decision will be entered under Rule 155.
P, a domestic corporation, acquired substantially all of
the stock of A, a foreign corporation. The…
2Cases cited12 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- National Railroad Passenger Corporation v. National Assn. of Railroad PassengersSupreme Court of the United States · 1974
- Naftel v. CommissionerUnited States Tax Court · 1985
- Bond v. CommissionerUnited States Tax Court · 1993
- Estate of O'Connor v. CommissionerUnited States Tax Court · 1977
7 more not listed; retrieve them via the Exa API.