112 T.C. No. 10
UNITED STATES TAX COURT
INTERLAKE CORPORATION, SUCCESSOR IN INTEREST TO INTERLAKE, INC.,
AND CONSOLIDATED SUBSIDIARIES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8258-96. Filed March 18, 1999.
P, as the result of a restructuring transaction,
became the successor common parent of a consolidated
group of corporations (the group). A, the former
common parent of the group, became a wholly owned
subsidiary of P. P then distributed, pro rata, to its
shareholders, all of the issued and outstanding common
shares of A, which became, as a result of the spinoff,
a separate publicly traded corporation.
Subsequent to the restructuring transaction, P and
the group incurred a consolidated net operating loss
(CNOL). P filed an application under sec. 6411,
I.R.C., for a tentative refund of income tax
attributable to the carryback of the postrestructuring
transaction CNOL to 1984, a prespinoff year during
which A controlled the group. A and its new group also
incurred a postrestructuring transaction CNOL for which
A filed an application under sec. 6411, I.R.C., for a
tentative refund of income tax attributable to the
carryback of its postrestructuring transaction CNOL to
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