Kohler Co. And Subsidiaries v. United States
Court of Appeals for the Federal Circuit
1Opinion of the Court
SCHALL, Circuit Judge.
This tax case presents us with two distinct issues. Kohler Co. and subsidiaries (“Koh-ler”) appeal from the November 8, 1995 final judgment of the United States Court of Fed eral Claims in Kohler Co. v. United States, 34 Fed. Cl. 379 (1995). The Court of Federal Claims held that the Internal Revenue Service (“IRS”) correctly precluded Kohler Co. from including Kohler Ltd., its wholly-owned Canadian subsidiary, in its consolidated tax return for 1985. Id. at 387. The court also held that the IRS’s determination that Koh-ler’s 1984 income was not clearly reflected through…
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