International Multifoods Corp. v. Commissioner
United States Tax Court
On Mar. 30, 1987, P, a domestic corporation, entered into an agreement with Borden to sell P's stock in Paty, a limitada organized under the laws of the Federal Republic of Brazil. P realized a loss upon the sale of the Paty stock, which P reported as a U.S. source loss for purposes of its foreign tax credit computation under sec. 904(a), I.R.C. R determined that the loss was foreign source. Held: P's loss is sourced in the United States.
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On Mar. 30, 1987, P, a domestic corporation, entered into an agreement with Borden to sell P's stock in Paty, a limitada organized under the laws of the Federal Republic of Brazil. P realized a loss upon the sale of the Paty stock, which P reported as a U.S. source loss for purposes of its foreign tax credit computation under sec. 904(a), I.R.C. R determined that the loss was foreign source. Held: P's loss is sourced in the United States. Sec. 865, I.R.C., which provides that income from the sale of noninventory personal property is generally sourced at the residence of the seller, is also…
1Opinion of the Court
Ruwe, Judge:
On March 26, 1992, respondent determined deficiencies in petitioner’s Federal income taxes as follows:
TYE Deficiency
2/28/87 . $2,962,380
2/29/88 . 3,592,402
Petitioner paid these deficiencies following receipt of its notice of deficiency and on June 1, 1992, filed a petition with this Court claiming an overpayment of income tax for each year.
In International Multifoods Corp. v. Commissioner, 108 T.C. 25 (1997), we disposed of several issues in this case. In an order accompanying the release of our opinion, we granted respondent’s motion to sever and hold the sole remaining issue in…
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