Former Member of a Controlled Group Can Deduct Loss on an Intercompany Sale: Turner Broadcasting System, Inc. v. Commissioner
In Turner Broadcasting System, Inc. v. Commissioner, a target corporation was acquired and simultaneously sold stock at a loss to the group that formerly controlled the target. The government challenged the loss under sections 311 and 267(f). Relying on Esmark v. Commissioner, the Tax Court allowed the loss. ...
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- Taxation Section