Grecian Magnesite Mining, Indus. & Shipping Co. v. Comm'r
United States Tax Court
In 2001 P, a foreign corporation, purchased an interest in PS, a U.S. limited liability company that was treated as a partnership for U.S. income tax purposes. From 2001 to 2008 income was allocated to P from PS, and P paid income tax in the United States.
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In 2001 P, a foreign corporation, purchased an interest in PS, a U.S. limited liability company that was treated as a partnership for U.S. income tax purposes. From 2001 to 2008 income was allocated to P from PS, and P paid income tax in the United States. In 2008 P's interest was redeemed by PS, and P received two liquidating payments, one in July 2008 and the second in January 2009 but deemed to have been made on December 31, 2008. P realized gain totaling over $6.2 million, of which $2.2 million was deemed attributable to U.S. real property interests (and which P now concedes is taxable…
1Opinion of the Court
GRECIAN MAGNESITE MINING, INDUSTRIAL & SHIPPING CO., SA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Grecian Magnesite Mining, Indus. & Shipping Co. v. Comm'r
Docket No. 19215-12
United States Tax Court
2017 U.S. Tax Ct. LEXIS 36; 149 T.C. No. 3;
July 13, 2017, Filed
Decision will be entered under Rule 155.
In 2001 P, a foreign corporation, purchased an interest in PS, a U.S. limited liability company that was treated as a partnership for U.S. income tax purposes. From 2001 to 2008 income was allocated to P from PS, and P paid income tax in the United States. In 2008 P's interest was…
2Cases cited17 opinions
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- TRW Inc. v. AndrewsSupreme Court of the United States · 2001
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- Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
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