HBM Holdings Company

Summary

The United States Tax Court granted the Commissioner’s motion and denied HBM Holdings’ motion for partial summary judgment, holding that Delavau is a predecessor of HBM, that the lonely‑parent rule does not exempt Delavau’s separate‑return years, that the founding members do not constitute an SRLY subgroup, and therefore the group is not entitled to consolidated net operating loss deductions for 2018, 2020, and 2021.