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Background
This case was submitted fully stipulated under Rule 122.
The stipulation of facts and the accompanying exhibits are
incorporated herein by this reference and found accordingly.
Petitioner, an accrual basis taxpayer, had its principal
offices in Maumee, Ohio, at the time it filed its petition
herein. Petitioner changed its name to Trinova from the Libbey-
Owens-Ford Company (LOF) on July 31, 1986. Petitioner timely
filed a consolidated Federal income tax return with certain of
its subsidiaries for the years at issue with the Internal Revenue
Service Center, Cincinnati, Ohio, or the Internal Revenue Service
office in Toledo, Ohio. Petitioner was engaged in the fluid
power and plastics businesses, and in the manufacture of glass.
The glass business was referred to as the "LOF Glass Division".
One of LOF's largest shareholders was Pilkington Brothers
(Pilkington), an English company, which owned 29 percent of
petitioner's common stock through its wholly owned U.S.
subsidiary, Pilkington Holdings, Inc. (Pilkington Holdings). Two
of petitioner's fourteen directors were associated with
Pilkington. In late 1985, Pilkington approached LOF and began
negotiations concerning the possibility of acquiring the glass
business.
2(...continued)
between subpart F income and non-subpart F income, will be
decided later by a separate opinion.
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