West Seattle National Financial from Seattle vmissioner of Interior Money, 288 F
The backdrop in this instance needs to a good the amount revolved inside the applying of Part 332. Throughout the Court’s viewpoint, you to Section wasn’t relevant.
Certain argument is made that kind of attract held by depositor-investors was not a course regarding inventory inside concept of Point 332 and this merger anywhere between Movie industry and Home is new merger regarding a daddy and you will an entirely-owned subsidiary. When you’re including result could well be possible, the newest Courtroom seems one just like the, as a matter of fact, the organization off Hollywood continued in home versus interruption, the need for the new reserve to own bad debts proceeded and you may performed maybe not cease and you will, therefore, new put aside really should not be recovered in order to earnings.
A look at the new cases, such two of this Routine, verifies it influence. 2d 47 (9th Cir. 1961); Calavo, Inc. Weiterlesen