115 T.C. No. 6
UNITED STATES TAX COURT
TEXTRON INC. AND SUBSIDIARY COMPANIES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20643-98. Filed August 7, 2000.
A filed a consolidated return with its wholly-
owned subsidiary (PR) in 1977. During that year, A
distributed a note to PR in redemption of PR’s shares
in A. In 1985, P acquired more than 80 percent of the
stock of A, and thereupon A and PR became members of
P’s consolidated group. In 1987, A redeemed the note
from PR. Later that year, PR liquidated into A. Held:
Under sec. 1.1502-14(d)(4), Income Tax Regs., P may not
take a deduction in 1987 for the capital loss PR
realized on the redemption of A’s note.
James P. Fuller, Kenneth B. Clark, and David L. Forst, for
petitioner.
Nancy B. Herbert and Ruth M. Spadaro, for respondent.
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011