Legal Opinion
New York Times Sales, Inc. v. Commissioner of Revenue
Massachusetts Appeals Court
Decided July 19, 1996No. 95-P-1339PublishedCited by 8 opinions
1Opinion of the CourtSmith, J.
The Commissioner of Revenue (commissioner) appeals from a decision of the Appellate Tax Board (board) granting the taxpayer, New York Times Sales, Inc.’s (Times Sales), requests for tax abatements. The commissioner had ruled that cash transfers from Times Sales to its parent, The New York Times Company, Inc. (Times Company or parent), were interest free intercompany loans, and as a result, G. L. c. 63, § 39A, authorized the commissioner to impute interest on such loans to Times Sales as “fair compensation” for the “services” it rendered to Times Company.1 See Commissioner of Rev. v.…
2Cases cited15 opinions
- Gene O. Clark and Faye Clark v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
- Alterman Foods, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1975
- Cornelius G. Noble and Pansy H. Noble v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1966
- Polaroid Corp. v. Commissioner of RevenueMassachusetts Supreme Judicial Court · 1984
- Koch v. Commissioner of RevenueMassachusetts Supreme Judicial Court · 1993
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3Cited by8 opinions
- United Parcel Service General Services Co. v. Director, Division of TaxationNew Jersey Superior Court Appellate Division · 2013
- Overnite Transportation Co. v. Commissioner of RevenueMassachusetts Appeals Court · 2002
- Tambrands, Inc. v. Commissioner of RevenueMassachusetts Appeals Court · 1999
- United Parcel Service General Services Co. v. Director, Division of TaxationNew Jersey Tax Court · 2009
- National Grid Holdings, Inc. v. Commissioner of RevenueMassachusetts Appeals Court · 2016
3 more not listed; retrieve them via the Exa API.