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TEXTRON INC. v. C.I.R.

No. 02-2455.

336 F.3d 26 (2003)

TEXTRON INC. and Subsidiary Companies, Petitioner, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, Appellee.

United States Court of Appeals, First Circuit.

Decided July 16, 2003.

Attorney(s) appearing for the Case

Kenneth B. Clark and James P. Fuller, with whom David L. Forst and Fenwick & West, were on the brief for appellant.

Kenneth W. Rosenberg, Attorney, Department of Justice, with whom Jonathan S. Cohen, Attorney, Department of Justice, and Eileen J. O'Connor, Assistant Attorney General, was on the brief for the Commissioner of Internal Revenue.

Before LIPEZ, Circuit Judge, PORFILIO, Senior Circuit Judge, HOWARD, Circuit Judge.

JOHN C. PORFILIO, Senior Circuit Judge.

Textron Inc. and Subsidiary Companies (Textron) appeals an order in the Tax Court holding its subsidiary, Paul Revere Corporation (Paul Revere), was not permitted to deduct its $14,934,745 capital loss in Textron's 1987 taxable year. We reverse.

Textron is the common parent of an affiliated group of corporations within the meaning of I.R.C. § 1504(a). The general rule of I.R.C. § 1001 requires consolidated...

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