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AMBAC INDUSTRIES, INC. v. COMMISSIONER

Docket No. 1665-70.

59 T.C. 670 (1973)

AMBAC INDUSTRIES, INC., FORMERLY KNOWN AS AMERICAN BOSCH ARMA CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 13, 1973.

Attorney(s) appearing for the Case

William H. Brayer, for the petitioner.

Rufus H. Leonard, Jr., and Steedly Young, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined a deficiency of $140,676.28 in petitioner's income tax for 1965. Petitioner has conceded all but one of the issues raised in the statutory notice of deficiency.

The disputed issue relates to the computation of petitioner's basis in the stock and debt of its former subsidiary and will require an interpretation of the pre-1966 consolidated return regulations.1 The...

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