Vulcan Materials Company v. United States

446 F.2d 690
CourtCourt of Appeals for the Fifth Circuit
DecidedJune 25, 1971
Docket30117_1
StatusPublished
Cited by28 cases

This text of 446 F.2d 690 (Vulcan Materials Company v. United States) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Vulcan Materials Company v. United States, 446 F.2d 690 (5th Cir. 1971).

Opinion

ALDISERT, Circuit Judge:

Two principal issues are presented by these appeals from the district court’s denial of federal income tax refunds: (I) whether organization or reorganization expenses incurred by appellant’s predecessors, and concededly capital in nature and not deductible when incurred, became deductible upon the occurrence of statutory mergers carried out pursuant to 26 U.S.C. § 368(a) (1) (A); (II) whether appellant met its burden of overcoming the Commissioner’s determination that one of its predecessors, Follans-bee Steel Corporation, had acquired two other corporations for the principal purpose of tax avoidance. If appellant did not satisfy this burden, it is conceded that net operating loss carryovers were properly disallowed under 26 U.S.C. § 269(a) (2).

A stipulation of facts with accompanying documentary exhibits constituted the sole evidence at trial. No oral testimony was offered. The salient facts are summarized in the opinion of the district court, 308 F.Supp. 53, 54-55 (N.D.Ala.1969):

On December 23, 1954, Consumers Company (Consumers) and Frontier Chemical Company (Frontier), both Delaware corporations, were merged into a third Delaware corporation theretofore named Follansbee Steel Corporation (Follansbee). Prior to the aforementioned merger, Follans-bee disposed of all of its operating assets. Upon merger, the corporation owned approximately nine million dollars in liquid assets and had an approximate six million dollar net operating loss. In the merger proceedings, the name of the surviving corporation was changed from Follansbee Steel Corporation to Union Chemical and Material Corporation (Union Chemical). On December 31, 1957, Union Chemical was merged into the plaintiff. Each of the aforementioned mergers constituted reorganizations within the meaning of Sec. 368(a) (1) (A) of the Internal Revenue Code of 1954 * * *.

In 1934, the predecessor of Consumers filed a petition in the United States District Court for the Northern District of Illinois for a reorganization under Section 77B of the Bankruptcy Act. During the period 1933 through 1937, various expenditures were incurred with respect to the reorganization and to the organization of the former corporation into Consumers. Likewise, Follansbee’s predecessor filed a petition in bankruptcy in 1934 and in 1940 was reorganized into Fol-lansbee Steel Corporation. In 1946, a further corporation merged with Fol-lansbee and as a result of the reorganization and merger, expenses were alleged to have been incurred. Each of the aforementioned expenditures is conceded to be capital in nature and thus not deductible when paid or incurred.

On its 1957 corporate income tax return, Union Chemical deducted all of the aforementioned expenses. A subsequent audit resulted in the disallowance of these deductions, followed by a deficiency assessment totalling $369,-453.93 which was paid. A claim for refund of this amount was filed and thereafter rejected on the theory that the aforementioned expenditures were capital in nature and not deductible upon merger.

*693 The Internal Revenue Service further refused to make a refund based on a depletion allowance on the ground that plaintiff had improperly carried over Follansbee’s premerger net operating losses in contravention of Sec. 269 of the 1954 Code. Although the deficiency which resulted from the carry-forward was not assessable due to the bar of the statute of limitations, it was nevertheless of sufficient size to offset any recovery to which the plaintiff might otherwise have been entitled. On March 24, 1965, plaintiff’s claim for refund was formally rejected.

-X- * * * •» -X-

Prior to December 23, 1954, the date on which Consumers and Frontier merged into Follansbee, the latter corporation disposed of all of its machinery, tools, inventory, etc., which it used in its steel operation; hence, the corporation was but a mere shell. However, on the date of merger its sole possessions consisted of approximately nine million dollars in liquid assets and approximately a six million dollar net operating loss which it could not utilize due to the abatement of its operations. The companies which merged into Follansbee were engaged in the stone and chemical business. Following the merger, the new entity continued to operate profitably. In each of the years 1955, 1956 and 1957, portions of the pre-merger net operating loss suffered by Follansbee were used to offset the profits of the Consumers and Frontier enterprises.

I.

Reorganization Expenses

It is well established that recapitalization or reorganization expenditures of a corporation are not ordinary and necessary business expenses but rather capital expenditures which are not deductible when incurred. General Banc-shares Corp. v. Commissioner, 326 F.2d 712 (8 Cir.), cert. denied, 379 U.S. 832, 85 S.Ct. 62, 13 L.Ed.2d 40 (1964); Bush Terminal Bldgs. Co. v. Commissioner, 204 F.2d 575 (2 Cir. 1953); Missouri-Kansas Pipe Line Co. v. Commissioner, 148 F.2d 460 (3 Cir. 1945). In Godfrey v. Commissioner, 335 F.2d 82, 85 (6 Cir. 1964), the court stated:

An expenditure is of a capital nature “where it results in the taxpayer’s acquisition or retention of a capital asset, or in the improvement or development of a capital asset in such a way that the benefit of the expenditure is enjoyed over a comparatively lengthy period of business operation.” Louisiana Land & Exploration Co. v. Commissioner, 7 T.C. 507, aff’d. 161 F.2d 842, C.A. 5 [(1947)] * * *.

While appellant concedes that the capital expenditures were not deductible when paid or incurred, the government acknowledges that capital expenditures of the nature here involved may be deducted upon the dissolution and liquidation of a corporation. Bryant Heater Co. v. Commissioner, 231 F.2d 938 (6 Cir. 1956); Commissioner of Internal Revenue v. Wayne Coal Mining Co., 209 F.2d 152 (3 Cir. 1954); Shellabarger Grain Products Co. v. Commissioner, 146 F.2d 177 (7 Cir. 1944); Hoppers Co. v. United States, 278 F.2d 946, 150 Ct.Cl. 556 (1960); Pacific Coast Biscuit Co. v. Commissioner, 32 B.T.A. 39 (1935); Malta Temple Assn. v. Commissioner, 16 B.T.A. 409 (1929).

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446 F.2d 690, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vulcan-materials-company-v-united-states-ca5-1971.