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H. K. PORTER CO. v. COMMISSIONER

Docket No. 8237-84.

87 T.C. 689 (1986)

H. K. PORTER COMPANY, INC., AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 29, 1986.

Attorney(s) appearing for the Case

C. J. Queenan, Jr., W. Henry Snyder, and David L. Ketter, for the petitioner.

Edward J. Laubach, Jr., for the respondent.

OPINION

CLAPP, Judge:

Respondent determined deficiencies in petitioner's 1978 and 1979 Federal income tax in the amounts of $105,281 and $745,161, respectively. After concessions, the issue for decision is whether section 332 applies to bar the recognition of gain or loss on the liquidation of H.K. Porter Australia, Pty., Ltd., petitioner's subsidiary.

This case was submitted under Rule 122, Tax Court Rules of Practice and Procedure. The stipulation...

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