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Legal Opinion

SDI Netherlands B v. f.k.a. SDI International B v. v. Commissioner

United States Tax Court

Decided October 2, 1996No. 23747-94Unknown

1Opinion of the Court

107 T.C. No. 10

UNITED STATES TAX COURT SDI NETHERLANDS B.V., f.k.a. SDI INTERNATIONAL B.V., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23747-94. Filed October 2, 1996. P was the licensee of a Bermuda corporation (SDI Bermuda) of worldwide rights to use computer software. P in turn licensed those rights for use in the United States to a U.S. corporation (SDI USA). P received royalties from SDI USA as well as from other licensees. P paid specified percentages of the royalties it received from its licensees to SDI Bermuda. P, SDI USA, and SDI Bermuda were members of a…

2Cases cited26 opinions

  1. Pallottini v. CommissionerUnited States Tax Court · 1988
  2. Jarvis v. CommissionerUnited States Tax Court · 1982
  3. Achiro v. CommissionerUnited States Tax Court · 1981
  4. Estate of Emerson v. CommissionerUnited States Tax Court · 1977
  5. Borchers v. CommissionerUnited States Tax Court · 1990

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