Legal Opinion

Dresser Industries, Inc. v. Commissioner

United States Tax Court

Decided June 19, 1989No. Docket Nos. 14531-85, 13531-86Published

Held, P is not entitled to net interest income against interest expense in determining the amount of deduction to be allocated and apportioned in computing the combined taxable income (CTI) of P and its DISC under sec. 994(a)(2), I.R.C. 1954. Held, further: Sec. 1.994-1(c)(6)(v), Income Tax Regs., is valid. The CTI of P and its DISC must be reduced by the full amount of discount incurred on the sale of export accounts receivable from P to its DISC.

1Opinion of the Court

Dresser Industries, Inc. and Consolidated Subsidiaries, Petitioners v. Commissioner of Internal Revenue, Respondent

Dresser Industries, Inc. v. Commissioner

Docket Nos. 14531-85, 13531-86

United States Tax Court

92 T.C. 1276; 1989 U.S. Tax Ct. LEXIS 91; 92 T.C. No. 85;

June 19, 1989. June 19, 1989, Filed

Decisions will be entered under Rule 155.

Held, P is not entitled to net interest income against interest expense in determining the amount of deduction to be allocated and apportioned in computing the combined taxable income (CTI) of P and its DISC under sec. 994(a)(2), I.R.C. 1954. Held, further:…

2Cases cited25 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  3. United States v. CorrellSupreme Court of the United States · 1967
  4. Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
  5. National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979

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