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Allied-Signal Inc., as Successor by Merger to Allied Corporation, (Formerly Allied Chemical Corporation) v. Commissioner of Internal Revenue Service, Alliedsignal Inc., (Formerly Allied-Signal Inc.)

Citations: 54 F.3d 767; 25 Envtl. L. Rep. (Envtl. Law Inst.) 21182; 40 ERC (BNA) 1660; 75 A.F.T.R.2d (RIA) 1287; 1995 U.S. App. LEXIS 5130Docket: 94-7336

Court: Court of Appeals for the Third Circuit; February 22, 1995; Federal Appellate Court

Narrative Opinion Summary

Allied-Signal Inc., as the successor by merger to Allied Corporation (formerly Allied Chemical Corporation), appealed a decision from the Commissioner of Internal Revenue Service regarding tax-related matters. The case, numbered 94-7336, was reviewed by the United States Court of Appeals for the Third Circuit. On February 23, 1995, the appellate court affirmed the decision of the lower court (C.I.R. No. 89-09662), maintaining the original ruling concerning the tax issues raised by Allied-Signal Inc. The case is documented as 54 F.3d 767, 40 ERC 1660, 75 A.F.T.R.2d 95-1287, 95-1 USTC P 50,151, and referenced in 25 Environmental Law Reporter 21,182.

Legal Issues Addressed

Appellate Review of Tax Decisions

Application: The United States Court of Appeals for the Third Circuit reviewed and affirmed the decision of the Commissioner of Internal Revenue Service concerning tax-related matters.

Reasoning: On February 23, 1995, the appellate court affirmed the decision of the lower court (C.I.R. No. 89-09662), maintaining the original ruling concerning the tax issues raised by Allied-Signal Inc.

Successor Liability in Tax Matters

Application: Allied-Signal Inc., as the successor by merger to Allied Corporation, was held liable for the tax issues under dispute in the case.

Reasoning: Allied-Signal Inc., as the successor by merger to Allied Corporation (formerly Allied Chemical Corporation), appealed a decision from the Commissioner of Internal Revenue Service regarding tax-related matters.