Computer Sciences Corp. v. Comm'r of Internal Revenue

2 Citing cases

  1. Manassas Airport Indus. Park, Inc. v. Comm'r of Internal Revenue

    66 T.C. 566 (U.S.T.C. 1976)

    (1) Petitioner was not availed of principally for the manufacture, construction, or production of property with a simultaneous view towards liquidation, as provided in section 341(b)(1)(A), because the view toward liquidation occurred after manufacture, construction, or production was completed. Computer Sciences Corp., 63 T.C. 327 (1975), Sec. 1.341-2(a)(3), Income Tax Regs.; (2) All manufacturing, construction, and production of the real property was completed by petitioner more than 3 years prior to the realization of gain by its shareholders and such property was, therefore, not a section 341 asset within the meaning of section 341(b)(3), Sec. 1.341-4(d), Income Tax Regs.;

  2. Coyle v. Comm'r of Internal Revenue (In re Estate of Diecks)

    65 T.C. 117 (U.S.T.C. 1975)   Cited 1 times

    Cable Vista was continuously involved in ‘manufacture, construction, or production of property’ in that it was continuously in the process of laying cables and acquiring and connecting new customers to its system. The creation of both tangible property (the cable system) and intangible property (such as franchises and goodwill) are within the reach of section 341. Computer Sciences Corp., 63 T.C. 327, 346-347 (1974); FTS Associates, Inc., 58 T.C. 207 (1972). Petitioner argues that section 341 is inapplicable to a business where production is continuous, but cites no authority, nor do we know of any, that would support this proposition.