Samson Investment Company and Subsidiaries - Page 28

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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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