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Article: SQUARE D COMPANY AND SUBSIDIARIES, petitioner v. COMMISSIONER OF INTERNAL REVENUE, respondent
- Article from:
- United States. Tax Court. Reports
- Article date:
- September 1, 2003
- Author:
CopyrightCopyright Superintendent of Documents Sep 1-Sep 30, 2003. Provided by ProQuest LLC. (Hide copyright information)
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SQUARE D COMPANY AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT Docket No. 6067-97. Filed September 26, 2003.
P was a publicly held U.S. corporation and, after its acquisition by a foreign corporation (S) through a reverse subsidiary merger, was a U.S. corpora
tion indirectly owned by S, during the years in issue. To finance the acquisition of P, S obtained a commitment from two banks to extend loans to a to-be-organized subsidiary equal to one-half the acquisition price, not to exceed $1.125 billion. The subsidiary was created for the purpose of acquirin
g P. It was to use the loan proceeds to purchase P's outstanding shares, at which time it would merge into P ...