Tsn liquidating corp
The basic arrangement was that Rubicon leased its aniline and DPA facilities to Uniroyal and Imperial, and manufactured the aniline and DPA for their benefit, for cost (,752,0, ,409,0) plus a set fee of 0,000 per year. is not a question of fact" subject to clearly erroneous review. Commissioner [71-2 USTC ¶ 9651], 450 F.2d 379, 387 (5th Cir. Uniroyal took all of Rubicon's DPA production and about 25-30 percent of Rubicon's aniline production; Imperial or its subsidiaries took the remainder of Rubicon's aniline production. In particular, Uniroyal sought to repay certain of its outstanding debts and to generate cash to fund its core businesses.
By early 1981, Uniroyal and Imperial began to discuss the possible transfer of Uniroyal's interests in Rubicon's MDI and TDI facilities. Some of the facts have been stipulated; the stipulations and the stipulated exhibits are incorporated herein by this reference. When the petition was filed in the instant case, Uniroyal's principal office was at Middlebury, Connecticut. (hereinafter sometimes referred to as Rubicon), a corporation organized in 1963 under Louisiana law. Because Rubicon received only 0,000 profit per year from its aniline and DPA production, most of Rubicon's total profits came from the sale of isocyanates. The following table shows Rubicon's income and retained earnings for 19.
Since joining GCG four years ago, his work has included numerous large and complex bankruptcy cases such as Motors Liquidation Company, et al.