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CANAL CORP. & SUBS. v. COMMISSIONER

Docket No. 14090-06.

135 T.C. 199 (2010)

CANAL CORPORATION AND SUBSIDIARIES, FORMERLY CHESAPEAKE CORPORATION AND SUBSIDIARIES, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed August 5, 2010.

Attorney(s) appearing for the Case

Clifton B. Cates III , Robert H. Wellen , and David D. Sherwood , for petitioner.

Curt M. Rubin , Matthew I. Root , and Steven N. Balahtsis , for respondent.

KROUPA, Judge.

Respondent determined a $183,458,9811 deficiency in petitioner's (Chesapeake)2 Federal income tax for 1999, the year at issue. Respondent asserts in his amended answer that Chesapeake owes a $36,691,796 substantial understatement of income tax penalty under section 6662(a)3 for 1999. We must determine whether Chesapeake's subsidiary's contribution of its assets...

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