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carry on substantially the same “trade or business”. See Glover
Packing Co. v. United States, 164 Ct. Cl. 572, 328 F.2d 342, 349
(1964). If, however, we conclude that CDC was merely temporarily
inactive or simply maintaining a low profile with the intent to
resume contract drilling when economically possible, then CDC
would be able to “continue” to carry on substantially the same
trade or business. See Six Seam Co. v. United States, 524 F.2d
347 (6th Cir. 1975).
We have considered a break in operations of a corporation
for reasons that indicated the resumption of operations was
reasonably to be anticipated to be a “temporary” ceasing of
operations and not a cessation of the conduct of the
corporation's regular trade or business. See Clarksdale Rubber
Co. v. Commissioner, supra; H.F. Ramsey Co. v. Commissioner,
supra. In H.F. Ramsey Co. v. Commissioner, supra at 504, we
found:
As jobs were completed by * * * [the taxpayer],
its equipment, when not needed on other jobs, was
brought to * * * [taxpayer's] equipment yard where it
was reconditioned. Many pieces of equipment were sold
for the best price available without sacrifice and the
proceeds from the sale were used to discharge the loan
from Wachovia Bank & Trust Co. Ramsey's primary aim at
this time was to complete contracts in progress and to
do everything necessary and possible to discharge all
of * * * [taxpayer's] debts and liabilities.
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