Legal Opinion

General Elec. Co. v. Commissioner

United States Tax Court

Decided July 13, 1995No. Docket No. 14715-92UnpublishedCited by 1 opinion

During its 1979 and 1980 taxable years, P, a domestic corporation, manufactured aircraft engines and thrust reversers, and sold these parts to airframe manufacturers. The airframe manufacturers assembled the parts into airframes and then sold the finished products (aircraft) to foreign purchasers.

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During its 1979 and 1980 taxable years, P, a domestic corporation, manufactured aircraft engines and thrust reversers, and sold these parts to airframe manufacturers. The airframe manufacturers assembled the parts into airframes and then sold the finished products (aircraft) to foreign purchasers. P sold the engines and the reversers to the airframe manufacturers through its wholly owned subsidiary, D, a domestic international sales corporation (DISC). P paid D commissions on these sales, and P now claims additional DISC commission deductions with respect to these commissions. Held: P is not…

1Opinion of the Court

GENERAL ELECTRIC COMPANY AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

General Elec. Co. v. Commissioner

Docket No. 14715-92

United States Tax Court

T.C. Memo 1995-306; 1995 Tax Ct. Memo LEXIS 313; 70 T.C.M. (CCH) 39;

July 13, 1995, Filed

During its 1979 and 1980 taxable years, P, a domestic corporation, manufactured aircraft engines and thrust reversers, and sold these parts to airframe manufacturers. The airframe manufacturers assembled the parts into airframes and then sold the finished products (aircraft) to foreign purchasers. P sold the engines and the reversers…

2Cases cited13 opinions

  1. United States v. American Trucking AssociationsSupreme Court of the United States · 1940
  2. Tennessee Valley Authority v. HillSupreme Court of the United States · 1978
  3. Cwt Farms, Inc. And Cwt International, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
  4. CWT Farms, Inc. v. CommissionerUnited States Tax Court · 1982
  5. Lecroy Research Systems Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1984

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

3Cited by1 opinion

  1. General Electric Company and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2001

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