Legal Opinion

Rent-A-Center, Inc. and Affiliated Subsidiaries v. Commissioner

United States Tax Court

Decided January 14, 2014No. 8320-09, 6909-10, 21627-10Published

1Opinion of the Court

142 T.C. No. 1

UNITED STATES TAX COURT RENT-A-CENTER, INC. AND AFFILIATED SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 8320-09, 6909-10, Filed January 14, 2014. 21627-10. P, a domestic corporation, is the parent of numerous wholly owned subsidiaries including L, a Bermudian corporation. P conducted its business through stores owned and operated by its subsidiaries. The other subsidiaries and L entered into contracts pursuant to which each subsidiary paid L an amount, determined by actuarial calculations and an allocation formula, relating to workers’…

2Cases cited32 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  3. Helvering v. Le GierseSupreme Court of the United States · 1941
  4. Sinclair Refining Co. v. Jenkins Petroleum Process Co.Supreme Court of the United States · 1933
  5. Rauenhorst v. Comm'rUnited States Tax Court · 2002

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