Legal Opinion
St. Jude Medical, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided September 9, 1994No. 93-2642PublishedCited by 18 opinions
1Opinion of the Court
MAGILL, Circuit Judge.
In this appeal, we are asked to decide the effect of Treasury Regulation § 1.861-8 (as amended in 1977) on computations requiring application of the intercompany pricing rules of the domestic international sales corporation (DISC) statute, I.R.C. §§ 991-997. St. Jude Medical, Inc. (St. Jude) challenges the United States Tax Court’s decision that the Commissioner of the Internal Revenue (the Commissioner) correctly assessed a tax deficiency against it for tax years 1981,1982, and 1983. The tax court found that, in DISC combined taxable income (CTI) computations, St. Jude…
2Cases cited6 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- Cottage Savings Assn. v. CommissionerSupreme Court of the United States · 1991
- Estate of Willard E. Robertson, Deceased, Walter G. Miller, Successor-Executor v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1994
- St. Jude Medical v. Comm'rUnited States Tax Court · 1991
1 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Boeing Co. v. United StatesSupreme Court of the United States · 2003
- General Dynamics Corp. v. CommissionerUnited States Tax Court · 1997
- Perkin-Elmer Corp. v. CommissionerUnited States Tax Court · 1994
- Boeing Co. v. United StatesCourt of Appeals for the Ninth Circuit · 2001
- International Paper Co. v. United StatesUnited States Court of Federal Claims · 1995
13 more not listed; retrieve them via the Exa API.