- 28 - 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.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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