Warbelow's Air Ventures v. Comm'r
United States Tax Court
P leased land from the State of Alaska to operate an airport. The leased land is surrounded by lands owned by a Native corporation and a federally recognized Native entity. P claimed the Indian employment credit (IEC) on its corporate tax return with respect to wages paid to employees who perform substantially all of their services for P at the airport. R disallowed the IEC.
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P leased land from the State of Alaska to operate an airport. The leased land is surrounded by lands owned by a Native corporation and a federally recognized Native entity. P claimed the Indian employment credit (IEC) on its corporate tax return with respect to wages paid to employees who perform substantially all of their services for P at the airport. R disallowed the IEC. Held: The term "within an Indian reservation" in I.R.C. sec. 45A(c)(1)(B) means located "on" an Indian reservation. Held, further, P does not qualify for the IEC because the airport is not located "within an Indian…
1Opinion of the Court
WARBELOW'S AIR VENTURES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Warbelow's Air Ventures v. Comm'r
No. 10351-00
United States Tax Court
118 T.C. 579; 2002 U.S. Tax Ct. LEXIS 37; 118 T.C. No. 37;
June 27, 2002, Filed
Petitioner not entitled to Indian employment credit with respect to wages paid to employees who perform substantially all their services in petitioner's employ at airport.
P leased land from the State of Alaska to operate an airport.
The leased land is surrounded by lands owned by a Native
corporation and a federally recognized Native entity. P claimed
the Indian…
2Cases cited9 opinions
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Burlington Northern Railroad v. Oklahoma Tax CommissionSupreme Court of the United States · 1987
- Alaska v. Native Village of Venetie Tribal GovernmentSupreme Court of the United States · 1998
- Doyon, Limited v. United StatesCourt of Appeals for the Federal Circuit · 2000
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