Legal Opinion

Philip Morris, Inc. v. Commissioner

United States Tax Court

Decided April 11, 1991No. Docket Nos. 28604-82, 33778-83, 38953-84Published

PM is the common parent of an affiliated group of corporations that filed consolidated returns for the years in issue. On June 1, 1978, PM, through NS, its acquisition subsidiary, acquired all the outstanding stock of S, a publicly traded corporation, in a hostile takeover. W-J was a subsidiary of S. On June 16, 1978, NS caused W-J to merge with and into S in a transaction that qualified as a liquidation under secs. 332 and 334(b)(1), I.R.C., as amended.

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PM is the common parent of an affiliated group of corporations that filed consolidated returns for the years in issue. On June 1, 1978, PM, through NS, its acquisition subsidiary, acquired all the outstanding stock of S, a publicly traded corporation, in a hostile takeover. W-J was a subsidiary of S. On June 16, 1978, NS caused W-J to merge with and into S in a transaction that qualified as a liquidation under secs. 332 and 334(b)(1), I.R.C., as amended. On June 19, 1978, NS caused S to merge with and into it pursuant to a liquidation under secs. 332 and 334(b)(2). In allocating NS's refined…

1Opinion of the Court

Philip Morris Incorporated and Consolidated Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent

Philip Morris, Inc. v. Commissioner

Docket Nos. 28604-82, 33778-83, 38953-841

United States Tax Court

96 T.C. 606; 1991 U.S. Tax Ct. LEXIS 29; 96 T.C. No. 23;

April 11, 1991, Filed

Decisions will be entered under Rule 155.

PM is the common parent of an affiliated group of corporations that filed consolidated returns for the years in issue. On June 1, 1978, PM, through NS, its acquisition subsidiary, acquired all the outstanding stock of S, a publicly traded corporation, in a hostile…

2Cases cited35 opinions

  1. Estate of Newhouse v. CommissionerUnited States Tax Court · 1990
  2. Grace Bros. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1949
  3. Richard M. Boe and Mary Lots Boe v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
  4. Jack Daniel Distillery, Lem Motlow, Prop., Inc. v. The United StatesUnited States Court of Claims · 1967
  5. Boe v. CommissionerUnited States Tax Court · 1961

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