Legal Opinion

Durovic v. Commissioner

United States Tax Court

Decided December 3, 1975No. Docket No. 1633-65PublishedCited by 11 opinions

This case, originally decided in 54 T.C. 1364 (1970), is before the Court on remand in part from the U.S. Court of Appeals for the Seventh Circuit (487 F. 2d 36): (1) For further exploration of the law and the fact relating to, and a proper determination of, the rate of exchange to be used in converting Argentine expenditures in pesos, incurred prior to petitioner's emigration to this country, into dollars, and (2) to permit this Court to determine whether petitioner is…

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This case, originally decided in 54 T.C. 1364 (1970), is before the Court on remand in part from the U.S. Court of Appeals for the Seventh Circuit (487 F. 2d 36): (1) For further exploration of the law and the fact relating to, and a proper determination of, the rate of exchange to be used in converting Argentine expenditures in pesos, incurred prior to petitioner's emigration to this country, into dollars, and (2) to permit this Court to determine whether petitioner is entitled to a deduction for the cost of 63,903 ampules distributed without charge. Held: 1. On these facts, the so-called…

1Opinion of the Court

SUPPLEMENTAL OPINION

Irwin, Judge:

In an opinion filed June 24,1970 (54 T.C. 1364 (1970)), this Court made certain findings with respect to three items which entered into the computation of the costs of goods sold with respect to the production of 200,000 ampules of the drug Krebiozen by Duga Illinois, a partnership in which petitioner held a 50-percent interest.

First, we determined that the raw material cost incurred in Argentina on January 26,1950, of the 2 grams, 35 centigrams of powder which was used to produce the 200,000 ampules of Krebiozen in the United States was M$N 3,005,0001…

2Cases cited39 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Barr v. United StatesSupreme Court of the United States · 1945
  3. Helvering v. WinmillSupreme Court of the United States · 1938
  4. Durovic v. CommissionerUnited States Tax Court · 1970
  5. Marko Durovic v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1973

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

3Cited by11 opinions

  1. Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
  2. Ternovsky v. CommissionerUnited States Tax Court · 1976
  3. American Home Products Corp. v. United StatesUnited States Court of Claims · 1979
  4. Marko Durovic v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1976
  5. Durovic v. CommissionerUnited States Tax Court · 1985

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

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