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UNIROYAL INCORPORATED v. COMMISSIONER

Docket No. 46733-86.

65 T.C.M. 2690 (1993)

T.C. Memo. 1993-214

Uniroyal Incorporated and Consolidated Subsidiaries v. Commissioner.

United States Tax Court.

Filed May 18, 1993.

Attorney(s) appearing for the Case

Philip S. Winterer, Joseph P. Moodhe, and Gary M. Friedman, for the petitioners. Stephen C. Best and Robert E. Marum, for the respondent.

Memorandum findings of fact and opinion

CHABOT, Judge:

Respondent determined a deficiency in Federal corporate income tax against petitioners1 for 19822 in the amount of $1,320,450.

After a concession by respondent, see infra note 14, the issue for decision is whether a $16,500,000 cash transfer3 to Uniroyal by a 50-percent subsidiary is to be taxed to Uniroyal...

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