ACM Partnership v. Commissioner

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March 5, 1997

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2844 Perfumes, Cosmetics, and Other Toilet Preparations
325611 Soap and Other Detergent Manufacturing
federal taxation
income tax
ACM Partnership v. Commissioner
T.C. Memo 1997-115, 1997 Tax Ct. Memo LEXIS 118
US
Federal Court
United States Tax Court
Laro

Summary

Issues are whether subject transactions lacked economic substance, foreign partner should be treated as a lender, and allocation of taxable gain had substantial economic effect.

See Also

Colgate's Bid to Reduce Federal Taxes Fails

Legal and Court Case Update
May 1997

In a complex transaction aimed at reducing federal taxes, Colgate, Merrill Lynch, and ABN Ambro Bank formed a partnership, ACM.