Legal Opinion
Koehring Company, a Wisconsin Corporation v. United States
Court of Appeals for the Seventh Circuit
Decided August 4, 1978No. 77-2016PublishedCited by 7 opinions
1Opinion of the Court
HARLINGTON WOOD, Jr., Circuit Judge.
The question presented in this appeal is whether the district court erred in finding that a foreign corporation partially owned by the Koehring Company was a “controlled foreign corporation” within the meaning of Section 957 of the Internal Revenue Code. We affirm.
The facts as found by the district court in its unreported opinion are as follows: Koehring Company (taxpayer) is a Wisconsin corporation engaged in the manufacture of heavy construction equipment. In 1959 Koehring acquired a Panamanian corporation which it renamed Koehring Overseas Corporation…
2Cases cited7 opinions
- Higgins v. SmithSupreme Court of the United States · 1940
- Garlock, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1973
- Garlock, Inc. v. CommissionerUnited States Tax Court · 1972
- Kraus v. CommissionerUnited States Tax Court · 1973
- Estate of Weiskopf v. CommissionerUnited States Tax Court · 1975
2 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- R.E. Dietz Corporation v. United StatesCourt of Appeals for the Second Circuit · 1991
- Framatome Connectors USA, Inc. v. Comm'rUnited States Tax Court · 2002
- Apple, Inc. v. Franchise Tax BoardCalifornia Court of Appeal · 2011
- Schering-Plough Corp. v. United StatesDistrict Court, D. New Jersey · 2009
- Altria Group, Inc. v. United StatesDistrict Court, E.D. Virginia · 2025
2 more not listed; retrieve them via the Exa API.