Legal Opinion

Ross Glove Co. v. Commissioner

United States Tax Court

Decided July 23, 1973No. Docket Nos. 7486-70, 3837-71, 3838-71, 3848-71, 3849-71PublishedCited by 59 opinions

P was president and controlling shareholder of a Wisconsin glove-manufacturing corporation, and he desired to establish a glove-manufacturing operation in the Philippines.

Read the full summary

P was president and controlling shareholder of a Wisconsin glove-manufacturing corporation, and he desired to establish a glove-manufacturing operation in the Philippines. In 1960, a Bahamian corporation was formed, with P as the controlling shareholder, for the primary purpose of manufacturing gloves in the Philippines, and such corporation did conduct the business of the Philippine operation, although P represented to the Philippine authorities that he was the sole proprietor of the Philippine operation. During 1961 and 1962, the Bahamian corporation provided sewing services, made advances,…

1Opinion of the Court

SimpsoN, Judge:

The respondent determined the following deficiencies in, and additions to, the petitioners’ income tax:

Petitioner Year Deficiency Sec. 6653(b) [2] Sec. 6664(a) addition addition Ross Glove Co.1961 1962 1963 1964 1966 1968 1969 Carl and Janet Ross__...._... 1961 1962 1963 1966 1966 1968 1969 $19,076.42 . 66,424.72 . 73,307.41 . 66,528.43 . 60.269.62 $30,129.76 . 66,389.64 . 17,247.13 . 86,234.69 42,617.34 $49.06 170,606.43 86,263.21 34.24 146,772.19 73,386.09 28.10 46,046.76 22,623.38 . 126,740.11 62,870.06 . 130,982.05 66,491.03 . 38.109.62 19,064.81 .

The respondent also…

2Cases cited74 opinions

  1. Lucas v. EarlSupreme Court of the United States · 1930
  2. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  3. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  4. James v. United StatesSupreme Court of the United States · 1961
  5. National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949

69 more not listed; retrieve them via the Exa API.

3Cited by59 opinions

  1. Magnon v. CommissionerUnited States Tax Court · 1980
  2. King's Court Mobile Home Park, Inc. v. CommissionerUnited States Tax Court · 1992
  3. Katz v. CommissionerUnited States Tax Court · 1988
  4. Northern Indiana Public Service Company v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Seventh Circuit · 1997
  5. Hospital Corp. of America v. CommissionerUnited States Tax Court · 1983

54 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API