- 81 -
Merrill Parent’s board of directors. As described in those
written summaries, the cross-chain sales of the issuing
corporations’ stock and the sales of the target corporations were
part of the same seamless web of corporate activity intended by
petitioner to culminate in the sale of the target corporations
outside the consolidated group. Under the test prescribed by
this Court in Niedermeyer v. Commissioner, 62 T.C. 280 (1974),
and other cases discussed herein, respondent properly integrated
the cross-chain sales with the related sales of the target
corporations to ascertain the tax consequences of the
transactions, and we sustain respondent’s determination.
We have considered the other arguments of the parties, and,
to the extent not discussed herein, we conclude that the
arguments are irrelevant, moot, or without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
Page: Previous 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 Last modified: May 25, 2011