Thermatool Corp. v. Department of Revenue Services

651 A.2d 763, 43 Conn. Super. Ct. 260, 43 Conn. Supp. 260, 1994 Conn. Super. LEXIS 1795
CourtConnecticut Superior Court
DecidedJuly 7, 1994
DocketFile 397787
StatusPublished
Cited by3 cases

This text of 651 A.2d 763 (Thermatool Corp. v. Department of Revenue Services) is published on Counsel Stack Legal Research, covering Connecticut Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Thermatool Corp. v. Department of Revenue Services, 651 A.2d 763, 43 Conn. Super. Ct. 260, 43 Conn. Supp. 260, 1994 Conn. Super. LEXIS 1795 (Colo. Ct. App. 1994).

Opinion

*261 Blue, J.

A corporation, it has been said, has no body to kick and no soul to damn. 1 Thermatool Corporation, the plaintiff in this tax appeal, may have no body to kick, but it has changed its corporate form enough to raise a difficult legal problem. After first merging with another corporation, it was later spun-out and reincorporated under its premerger name. The question presented in this case is whether it can take advantage of a net operating loss incurred by its premerger predecessor. After an examination of all of the relevant circumstances, I conclude that it may properly do so.

The parties in this case have submitted a written stipulation of facts. In addition, a number of documentary exhibits and the testimony of some corporate officials were submitted at an evidentiary hearing. From these submissions, the following facts are found.

Prior to 1984, a New Jersey corporation named Inductotherm Industries, Inc. (“Industries”) had two wholly owned subsidiary corporations: Thermatool Corporation (“Thermatool I”) and Inductotherm Corporation (“Inductotherm”). The relationship of these corporations is represented by the following chart:

Industries
Thermatool I
Inductotherm

Inductotherm is a New Jersey corporation. Thermatool I was incorporated in Connecticut in 1974. It engaged in the specialized business of making high frequency welding equipment. During the tax years ending April 30, 1993, and April 30, 1984, it incurrred substantial net operating losses.

These losses made Thermatool I an attractive merger prospect for federal income tax purposes. On May 1, *262 1984, Thermatool I and Inductotherm merged. This was a statutory merger 2 in which Inductotherm became the surviving corporation. The directors and officers of Inductotherm became the directors and officers of the surviving corporation. The certificate of incorporation and bylaws of Inductotherm likewise became the certificate of incorporation and bylaws of the surviving corporation. Both corporations, as already mentioned, had been wholly owned by Industries. The shares of Inductotherm became the shares of the surviving corporation. The shares of Thermatool I were surrendered and automatically cancelled. The post-merger relationship of the corporations in question is represented by the following chart:

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It is clear from the evidence that this was entirely a marriage of convenience for federal tax purposes only. Inductotherm deducted the net operating loss carried forward from Thermatool I on its federal income tax return for the fiscal year ending April 30, 1985, pursuant to § 381 of the Internal Revenue Code of 1954.

*263 It is conceded that Inductotherm could not deduct this loss on its Connecticut corporation business tax return. See Golf Digest/Tennis, Inc. v. Dubno, 203 Conn. 455, 525 A.2d 106 (1987) (Golf Digest). Apart from the federal tax return and the legal formalities of the merger already mentioned, however, the business enterprise that had been performed by Thermatool I (now known as “the Thermatool Division of Inductotherm Corporation”) retained an ongoing, separate existence. It had what the written stipulation refers to as “separate and continued management.” It was recognized to be a separate division of Inductotherm. Its employees did not change, apart from normal turnover. Its clientele did not change, and its business did not change. Employees and customers dealing with the business would not have noticed the difference except for minor changes in the corporate stationery and paycheck stubs. In addition, the ultimate owner of the business, Industries, remained constant.

By the close of the fiscal year ending April 30,1985, the merger had accomplished its limited purpose. There being no other magic in the marriage, the union was quickly dissolved. On May 1,1985, in the words of the stipulation, “the Plaintiff, Thermatool Corporation, was spun-out in its entirety as a separate corporation, continuing as a wholly owned subsidiary of Inductotherm Industries, Inc.” In practice, it was explained at the hearing, this meant that a new corporation was incorporated in Connecticut under the name of Thermatool Corporation. This “Thermatool Corporation,” which is the plaintiff in this case, will hereinafter be referred to as “Thermatool II.” The assets and liabilities of the Thermatool Division of Inductotherm Corporation were transferred to Thermatool II by Inductotherm in exchange for all of Thermatool IPs stock. Inductotherm then declared a stock dividend and transferred this *264 stock to Industries. The relationship of the corporations after the spin-out is represented by the following chart:

Industries
Thermatool II
Inductotherm

It is clear from the evidence that, apart from the legal changes just mentioned, the spin-out did not affect the business enterprise of Thermatool II. That business continued to be the same as it had been not only prior to the spin-out but prior to the preceding merger. The assets, employees, customers, and stock ownership of the company were unaltered. In fact, it appears from the evidence that the only difference between Thermatool I and the Lazarus-like Thermatool II is the fact that they have different certificates of incorporation.

But is Thermatool I the same entity as Thermatool II for purposes of the Connecticut corporation business tax? This question has arisen because Thermatool II wishes to deduct the premerger net operating losses of Thermatool I. The department of revenue services (department) disallowed such a deduction, and this appeal followed.

“Unlike § 381 of the Internal Revenue Code of 1954, [General Statutes] § 12-217 does not specifically address the question of the ability of a surviving corporation to deduct as a carryover the net operating losses attributable to a consolidated corporation.” Golf Digest, supra, 203 Conn. 460. Section 12-217 provides that operating losses “shall be deductible . . . in each of the five income years following [the] loss year,” but the language just quoted does not address the question of who, if anyone, may deduct the losses of a merged corporation. The rather lengthy text of § 12-217 elsewhere refers to “the taxpayer,” and it is safe to assume *265 that any losses that are, in fact, deductible, will be deducted by “the taxpayer,” but this, too, does not address the question of what losses may be deducted by a merged (or spun-out) corporate “taxpayer.” The ultimate question that must be asked under the statute is whether the “taxpayer” deducting the loss is the “taxpayer” that incurred the loss. See Libson Shops, Inc. v. Koehler,

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Bluebook (online)
651 A.2d 763, 43 Conn. Super. Ct. 260, 43 Conn. Supp. 260, 1994 Conn. Super. LEXIS 1795, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thermatool-corp-v-department-of-revenue-services-connsuperct-1994.