Covil Insulation Co. v. Commissioner

65 T.C. 364, 1975 U.S. Tax Ct. LEXIS 27
CourtUnited States Tax Court
DecidedNovember 20, 1975
DocketDocket No. 7369-72
StatusPublished
Cited by17 cases

This text of 65 T.C. 364 (Covil Insulation Co. v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Covil Insulation Co. v. Commissioner, 65 T.C. 364, 1975 U.S. Tax Ct. LEXIS 27 (tax 1975).

Opinion

OPINION

Section 15014 permits an affiliated group of corporations to file a consolidated income tax return, in lieu of separate returns, for each taxable year. In granting this privilege, Congress did not attempt to prescribe detailed rules governing the determination of the income tax liability of members of the affiliated group. Rather, section 15025 authorizes the Secretary or his delegate to prescribe such regulations as he may deem necessary in order to clearly reflect the affiliated group’s income tax liability.

Under the prescribed regulations, the current earnings or losses of each member of the consolidated group enter into the computation of consolidated income, section 1.1502-11, Income Tax Regs. The losses of one affiliate may offset the profits of another and thus serve to reduce or eliminate consolidated income. Losses of a subsidiary may be utilized in this matter without limitation, even if the amount of utilized losses exceeds the group’s basis in the affiliate’s stock. As a result, the group’s tax liability may be distorted since the tax losses may exceed the economic losses. This distortion is eliminated, however, through the vehicle of compensating adjustments to the group’s basis in the affiliate’s stock.

Section 1.1502-32, Income Tax Regs., entitled “Investment adjustment,” and section 1.1502-19, Income Tax Regs., entitled “Excess losses,” deal with this problem. Under section 1.1502-32,6 Income Tax Regs., the impact of the subsidiary’s losses (and gains) is reflected in annual adjustments to the group’s basis in the subsidiary’s stock. The adjustments are of two kinds— positive and negative. Generally, the subsidiary’s undistributed earnings and profits, which contribute to consolidated income, necessitate a positive adjustment which increases the group’s basis in the stock. Losses of the subsidiary used to reduce the group’s consolidated income require negative adjustments which decrease the group’s basis in that stock. The adjustments are netted at the end of each taxable year. If the net negative adjustments exceed the group’s basis in the stock, an “excess loss account” — a negative basis for the stock — results. Sec. 1.1502-32(e)(1),7 Income Tax Regs.

When all of the subsidiary’s stock is disposed of, the members of the affiliated group owning the stock are required to include the balance of the “excess loss account” in income. See sec. 1.1502-19(a)(l),8 Income Tax Regs. The income, in most cases, is taxable as gain from the sale or exchange of stock. However, where, as in the instant case, the subsidiary is insolvent, the income is treated as ordinary income. Sec. 1.1502-19(a)(2),9 Income Tax Regs.

The term “disposed of” or “disposition” is given a rather broad meaning. Sec. 1.1502-19(b)(2),10 Income Tax Regs. With exceptions not here relevant, a member is considered to have disposed of all its shares in the subsidiary on the last day of its taxable year in which, among other situations, the subsidiary’s stock is wholly worthless or in which 10 percent or less of the face amount of any obligation for which the subsidiary is liable is recoverable at maturity by its creditors.

The group is thus able to reduce its consolidated income by loss deductions which are in excess of its true economic losses. It may be that these losses are temporary and the subsidiary will create enough earnings and profits later to eliminate the excess loss account. See Peel, Consolidated Tax Returns 227-228 (2d ed. 1973). If, however, the stock is disposed of prior to the subsidiary’s economic turnaround, the utilized excess losses are the practical equivalent of an “amount realized” in excess of the group’s investment and are logically includable in consolidated income. Sec. 1.1502-19(a), Income Tax Regs.

1. The 1968 Consolidated Income

Petitioner concedes that its Imesco stock was worthless in 1968, that Imesco could not pay its debts at the end of that year, that Imesco was insolvent within the meaning of applicable regulations, and that these regulations, if valid, would require the excess loss account of $118,661.01 to be included in the consolidated income for 1968. But petitioner contends that section 1.1502-32(e), Income Tax Regs., requiring a parent corporation filing a consolidated return to reduce its basis in its subsidiary’s stock to a figure below zero is invalid. Petitioner also challenges the validity of section 1.1502-19(a), Income Tax Regs., requiring the parent to include in income the amount of the excess loss account upon a disposition of the subsidiary’s stock.

In weighing petitioner’s attack on these consolidated return regulations, we begin with the principle that the Income Tax Regulations “should not be overruled except for weighty reasons.” Commissioner v. South Texas Co., 333 U.S. 496, 501 (1948). Moreover, section 1502 expressly authorizes the issuance of regulations in this area to deal with the complex problems created by the filing of consolidated returns, thus providing an added reason for upholding such a regulation unless it is clearly contrary to the will of Congress. Commissioner v. South Texas Co., supra at 503; Regal, Inc., 53 T.C. 261, 263-264 (1969), affd. per curiam 435 F.2d 922 (2d Cir. 1970); Union Electric Co. of Missouri v. United States, 158 Ct. Cl. 479, 486, 305 F.2d 850, 854(1962).

Further, exercise of the privilege of filing consolidated returns required petitioner to “consent to all the consolidated return regulations prescribed under section 1502 prior to the last day prescribed by law for the filing of such return.” Sec. 1501; Ilfeld Co. v. Hernandez, 292 U.S. 62 (1934). As emphasized by petitioner, this consent does not preclude a challenge to arbitrary regulations. See Joseph Weidenhoff, Inc., 32 T.C. 1222, 1242 (1959). However, when petitioner filed its first consolidated return in 1967, it was no doubt aware that the regulations permitted it to utilize Imesco’s losses to offset its income even if those losses exceeded its basis in the Imesco stock and that the same regulations, in clearly defined circumstances, provide for a recapture of such excess deductions. The burden of the excess loss account provisions must be accepted with the benefit of unlimited access to the subsidiary’s losses. See Georgia-Pacific Corp., 63 T.C. 790, 802 (1975).

We think the challenged regulations reflect a permissible exercise of the rulemaking power granted by section 1502. Indeed, the facts of this case amply demonstrate their reasonableness. Petitioner’s investment in Imesco was only $45,005, comprised of the $5 paid to acquire Imesco’s stock and the $45,000 indebtedness which petitioner capitalized. Yet Imesco’s losses, allowed as deductions in computing the tax results of the consolidated group, far exceeded that investment. They are as follows:

1967 loss offset against Covil’s income_1$83,022.39,

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Covil Insulation Co. v. Commissioner
65 T.C. 364 (U.S. Tax Court, 1975)

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Bluebook (online)
65 T.C. 364, 1975 U.S. Tax Ct. LEXIS 27, Counsel Stack Legal Research, https://law.counselstack.com/opinion/covil-insulation-co-v-commissioner-tax-1975.