Acme Steel Company (formerly known as Interlake, Inc., and now known as Acme Metals, Inc.) and Consolidated Subsidiaries - Page 1

                                 T.C. Memo. 2003-118                                  

                               UNITED STATES TAX COURT                                

               ACME STEEL COMPANY (formerly known as Interlake, Inc.,                 
               and now known as Acme Metals, Inc.) AND CONSOLIDATED                   
                    SUBSIDIARIES, Petitioners v. COMMISSIONER OF                      
                            INTERNAL REVENUE, Respondent                              

               Docket No. 7885-94.              Filed April 28, 2003.                 

                    P was the common parent of an affiliated group                    
               that was restructured in 1986.  In 1986, pursuant to                   
               the restructuring plan, P formed a subsidiary, I.                      
               Following the formation of I, P became a subsidiary of                 
               I through an inversion.  I then distributed, pro rata                  
               to its shareholders in a spinoff, all the issued and                   
               outstanding common shares of P, which continued to hold                
               all the shares of one pre-existing subsidiary of P.                    
                    Following the restructuring and spinoff, P filed a                
               consolidated Form 1120, U.S. Corporation Income Tax                    
               Return, for a 27-week 1986 tax year claiming a                         
               consolidated net operating loss (CNOL).  P filed a Form                
               1139, Application for Tentative Refund under sec. 6411,                
               I.R.C., carrying back the CNOL to the affiliated                       
               group’s 1981 and 1984 tax years and requesting                         
               tentative refunds for 1981 and 1984.  I filed a                        
               consolidated U.S. corporation income tax return for a                  
               52-week 1986 tax year claiming a CNOL.  I also filed an                

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