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Times Mirror - a reflection of the past.
- Article from:
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The Tax Adviser
- Article date:
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April 1, 2006
- Author:
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Copyright informationCOPYRIGHT 2006 American Institute of CPA's. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan. All inquiries regarding rights should be directed to the Gale Group. (Hide copyright information)
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In Tribune Co., 125 TC No. 8 (2005) (Times Mirror), the Tax Court held that a corporate reorganization was not tax flee under Sec. 368(a)(1)(A) and (B) and (a)(2)(E). Rather, the transaction was characterized as a sale for Federal tax purposes. While the decision led to a great deal of discussion and analysis within corporate tax circles, the court's holding is in fact nothing more than the continuous application of the economic-substance, business-purpose and sham-transaction doctrines to corporate reorganizations.
Times Mirror Decision
At a time of major changes in the legal publishing industry, Times Mirror Co., Inc., decided to divest itself of Matthew Bender & ...
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401 words
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