Legal Opinion
Tiffany-Davis Drug Co. v. Commission Oregon Food Stores, Inc.
Oregon Tax Court
Decided December 27, 1968PublishedCited by 1 opinion
1Opinion of the Court
Edward H. Howell, Judge.
The above two cases have been consolidated for decision.
The sole question presented is whether net operating losses incurred by subsidiary corporations prior to their liquidation into the parent corporation in a tax-free merger are deductible by the parent corporation in the years following the merger of the companies.
The facts have been stipulated.
Prior to their liquidation Tiffany-Davis #1, Tiffany-Davis §2, Tiffany-Davis #3 and Tiffany-Davis #4 were corporations which were wholly-owned by the parent corporation, Tiffany-Davis Drug Co. Tiffany-Davis #1 was liquidated…
2Cases cited4 opinions
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Helvering v. Metropolitan Edison Co.Supreme Court of the United States · 1939
- Western Maryland Railway Co. v. United StatesDistrict Court, D. Maryland · 1968
- Gamble v. State Tax CommissionOregon Supreme Court · 1967
3Cited by1 opinion
- Tiffany-Davis Drug Co. v. Department of RevenueOregon Supreme Court · 1970