First Chicago Corp. v. Commissioner
United States Tax Court
S, a domestic bank, and its related subsidiaries (consolidated affiliates) purchased shares in F, a foreign bank. The purchase was pursuant to and in connection with various agreements between S (including its subsidiaries) and F which provided for the business relationship between S and F. Under the agreements, it was intended that S and/or its subsidiaries would, in the aggregate, hold at least 10 percent of F's voting shares.
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S, a domestic bank, and its related subsidiaries (consolidated affiliates) purchased shares in F, a foreign bank. The purchase was pursuant to and in connection with various agreements between S (including its subsidiaries) and F which provided for the business relationship between S and F. Under the agreements, it was intended that S and/or its subsidiaries would, in the aggregate, hold at least 10 percent of F's voting shares. During the period in issue, S and its subsidiaries may have, in the aggregate, held 10 percent of the voting shares of F, but none of the S affiliates, at any time,…
1Opinion of the Court
GERBER, Judge:
Respondent, in a notice of deficiency dated February 4, 1987, determined a $3,993,041 deficiency in petitioner’s 1983 corporate income tax. The issue considered in this opinion concerns petitioner’s foreign tax credit.1 In conjunction with respondent’s 1983 determination, petitioner’s taxable years 1978 through 1982 have some bearing on this issue because of the effect of the foreign tax credit carryover from those years to 1983. The specific foreign tax area under consideration is whether petitioner and/or its affiliated group is entitled to the section 902(a)2 deemed paid…
2Cases cited24 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Helvering v. HorstSupreme Court of the United States · 1940
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
19 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- BUNNEY v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2000
- First Chicago Nbd Corporation v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1998
- PSB Holdings, Inc. v. Comm'rUnited States Tax Court · 2007
- Union Oil Co. v. CommissionerUnited States Tax Court · 1993
- Willamette Industries, Inc. v. CommissionerUnited States Tax Court · 1991
10 more not listed; retrieve them via the Exa API.