Legal Opinion
Caterpillar Tractor Co. v. United States
United States Court of Claims
Decided December 13, 1978No. 212-76PublishedCited by 44 opinions
1Opinion of the CourtBennett, Judge
The plaintiff, Caterpillar Tractor Company (Caterpillar), seeks to recover overpayments of federal income taxes and interest for the taxable year ending December 31, 1972. The case concerns the propriety of deductions for sales commissions paid to plaintiffs wholly owned subsidiary, Caterpillar Panamerican Company (CATPAC). Allowance of these deductions depends on whether CATPAC qualifies as a Domestic International Sales Corporation (DISC) under I.R.C. §§ 991-997. We think it does. This case is before the court on the parties’ stipulations of facts.
Caterpillar is a domestic corporation which…
2Cases cited11 opinions
- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- Commissioner v. AckerSupreme Court of the United States · 1959
- Koshland v. HelveringSupreme Court of the United States · 1936
- United States v. CalamaroSupreme Court of the United States · 1957
- Neuberger v. CommissionerSupreme Court of the United States · 1940
6 more not listed; retrieve them via the Exa API.
3Cited by44 opinions
- Louise J. Hamlet v. United StatesCourt of Appeals for the Federal Circuit · 1995
- Cwt Farms, Inc. And Cwt International, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
- Capitol Fed. Sav. & Loan Ass'n v. CommissionerUnited States Tax Court · 1991
- CWT Farms, Inc. v. CommissionerUnited States Tax Court · 1982
- Fiorentino v. United StatesUnited States Court of Claims · 1979
39 more not listed; retrieve them via the Exa API.