Archie L. and Louise B. Honbarrier - Page 3




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               RUWE, Judge:  Respondent determined a deficiency in Archie             
          L. and Louise B. Honbarrier’s Federal income tax for 1993 in the            
          amount of $2,090,149.  Respondent determined a deficiency in                
          Colonial Motor Freight Line, Inc.’s (Colonial) Federal income tax           
          for 1993 in the amount of $27,374.                                          
               The sole issue for decision is whether the merger of                   
          Colonial into Central Transport, Inc. (Central), on December 31,            
          1993, qualifies as a tax-free reorganization within the meaning             
          of section 368(a)(1)(A).1                                                   
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, first supplemental stipulation of                 
          facts, and the attached exhibits are incorporated herein by this            
          reference.  Mr. and Mrs. Honbarrier resided in High Point, North            
          Carolina, at the time they filed their petition.  At the time               
          Central filed its petition as successor to Colonial, its                    
          principal place of business was High Point, North Carolina.                 
          Colonial                                                                    
               Colonial was incorporated in 1941.  Colonial was a trucking            
          company that operated as a common carrier of packaged freight.              
          The company principally transported furniture manufactured in               



               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code and income tax regulations in effect              
          for the year in issue, and all Rule references are to the Tax               
          Court Rules of Practice and Procedure.                                      





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