Mars, Inc. v. Commissioner
United States Tax Court
Ps, which file a consolidated return, are the only partners of MIC, a French partnership. MIC "transformed" its juridical status pursuant to the laws of France from a French partnership into a French corporation (MICSA). The transformation of MIC into MICSA was motivated by business reasons.
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Ps, which file a consolidated return, are the only partners of MIC, a French partnership. MIC "transformed" its juridical status pursuant to the laws of France from a French partnership into a French corporation (MICSA). The transformation of MIC into MICSA was motivated by business reasons. Held, the transformation of MIC into MICSA was not in pursuance of a plan having as one of its principal purposes the avoidance of Federal income tax within the meaning of sec. 367, I.R.C. 1954. Hershey Foods Corp. v. Commissioner, 76 T.C. 312 (1981), followed. Held, further, the transformation is not a…
1Opinion of the Court
Mars, Incorporated, and Uncle Ben's, Inc., Petitioners v. Commissioner of Internal Revenue, Respondent
Mars, Inc. v. Commissioner
Docket No. 39472-85T
United States Tax Court
88 T.C. 428; 1987 U.S. Tax Ct. LEXIS 19; 88 T.C. No. 19;
February 11, 1987. February 11, 1987, Filed
Decision will be entered for the petitioners.
Ps, which file a consolidated return, are the only partners of MIC, a French partnership. MIC "transformed" its juridical status pursuant to the laws of France from a French partnership into a French corporation (MICSA). The transformation of MIC into MICSA was motivated by business…
2Cases cited10 opinions
- Consolo v. Federal Maritime CommissionSupreme Court of the United States · 1966
- United States v. Southwestern Cable Co.Supreme Court of the United States · 1968
- Rainwater v. United StatesSupreme Court of the United States · 1958
- Hillsboro National Bank v. CommissionerSupreme Court of the United States · 1983
- Terry v. TubmanSupreme Court of the United States · 1876
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