Brown-Forman Corp. v. Commissioner
United States Tax Court
Manufacturer of alcoholic beverages paid Federal excise tax on distilled spirits sold domestically and utilized DISC as commission agent for export sales of its liqueur product. Held, for purposes of computing the overall profit percentage limitation (OPPL) under sec. 1.994-2, Income Tax Regs., "gross receipts" from domestic sales includes the total sales proceeds received from customers, without reduction for manufacturer's payment of excise tax on distilled spirits.
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Manufacturer of alcoholic beverages paid Federal excise tax on distilled spirits sold domestically and utilized DISC as commission agent for export sales of its liqueur product. Held, for purposes of computing the overall profit percentage limitation (OPPL) under sec. 1.994-2, Income Tax Regs., "gross receipts" from domestic sales includes the total sales proceeds received from customers, without reduction for manufacturer's payment of excise tax on distilled spirits. Held, further, for purposes of the OPPL, gross receipts from export sales does not include any amount attributable to the…
1Opinion of the Court
Brown-Forman Corporation (A Delaware Corporation), Successor by Merger to Brown-Forman Corporation (A Tennessee Corporation), Successor in Interest to Southern Comfort Corporation (A Delaware Corporation), Petitioner 1 v. Commissioner of Internal Revenue, Respondent
Brown-Forman Corp. v. Commissioner
Docket No. 27494-87
United States Tax Court
94 T.C. 919; 1990 U.S. Tax Ct. LEXIS 63; 94 T.C. No. 58;
June 25, 1990, Filed
Decision will be entered under Rule 155.
Manufacturer of alcoholic beverages paid Federal excise tax on distilled spirits sold domestically and utilized DISC as commission agent for…
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