Legal Opinion

Grecian Magnesite Mining, Indus. & Shipping Co. v. Comm'r

United States Tax Court

Decided July 13, 2017No. Docket No. 19215-12Published

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

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Auer v. RobbinsSupreme Court of the United States · 1997
  3. TRW Inc. v. AndrewsSupreme Court of the United States · 2001
  4. United States v. BoyleSupreme Court of the United States · 1985
  5. Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000

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