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FRUIT OF THE LOOM, INC. v. COMMISSIONER

Docket No. 26234-92.

68 T.C.M. 867 (1994)

T.C. Memo. 1994-492

Fruit of the Loom, Inc., Transferee of the Assets of, and Primarily Liable as Successor by Merger to, Northwest Industries, Inc., Transferee of the Assets of, and Primarily Liable as Successor by Merger to, Philadelphia & Reading Corporation v. Commissioner.

United States Tax Court.

Filed October 6, 1994.

Attorney(s) appearing for the Case

Thomas Kittle-Kamp, Thomas C. Durham, 190 S. LaSalle St., Chicago, Ill., and Frederic L. Hahn, 3 First National Plaza, Chicago, Ill., for the petitioner.1 James S. Stanis, for the respondent.

Memorandum Opinion

LARO, Judge:

The parties submitted this case to the Court fully stipulated under Rule 122(a).2 Fruit of the Loom, Inc., petitioned the Court on November 24, 1992, to redetermine respondent's alternative determinations of a $7,135,865 deficiency in the 1966 Federal income tax of a predecessor corporation or a $7,296,000 deficiency in the 1967 Federal income tax of that predecessor corporation. Respondent determined...

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