Philip Morris, Inc. v. Commissioner
United States Tax Court
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…
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- Richard M. Boe and Mary Lots Boe v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Jack Daniel Distillery, Lem Motlow, Prop., Inc. v. The United StatesUnited States Court of Claims · 1967
- Boe v. CommissionerUnited States Tax Court · 1961
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