Hewlett-Packard Co. v. Commissioner
United States Tax Court
1. Held, petitioner substantially complied with the directions of sec. 1.964-1(c)(3), Income Tax Regs., prescribing the procedure for the election of depreciation accounting methods, and the earnings and profits of three of its controlled foreign subsidiaries for the taxable years ended Oct. 31 of 1967 through 1970, properly reflected adjustments for accelerated depreciation. 2. Held, further, petitioner did not satisfy the "minimum overall tax burden" test prescribed by…
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1. Held, petitioner substantially complied with the directions of sec. 1.964-1(c)(3), Income Tax Regs., prescribing the procedure for the election of depreciation accounting methods, and the earnings and profits of three of its controlled foreign subsidiaries for the taxable years ended Oct. 31 of 1967 through 1970, properly reflected adjustments for accelerated depreciation. 2. Held, further, petitioner did not satisfy the "minimum overall tax burden" test prescribed by sec. 1.963-4(a), Income Tax Regs., and is not entitled to exclude for its taxable year ended Oct. 31, 1968, the subpart F…
1Opinion of the Court
Featherston, Judge:
Respondent determined deficiencies in petitioner’s Federal income tax as follows:
TYE Oct. 31-Amount of deficiency TYE Oct. 31— Amount of deficiency
1967. $158,119.01 1969. $582,216.03
1968. 135,309.01 1970. 490,022.34
Other issues having been settled by the parties or severed for separate trial,1 those remaining for decision are as follows:(1) Whether petitioner effectively elected for its taxable years ended October 31 of 1967 through 1970, a method of accelerated depreciation for computing the earnings and profits of three of its controlled foreign subsidiaries when it filed…
2Cases cited9 opinions
- Bogardus v. CommissionerSupreme Court of the United States · 1937
- Reaver v. CommissionerUnited States Tax Court · 1964
- Sperapani v. CommissionerUnited States Tax Court · 1964
- Cary v. CommissionerUnited States Tax Court · 1963
- Columbia Iron & Metal Co. v. CommissionerUnited States Tax Court · 1973
4 more not listed; retrieve them via the Exa API.
3Cited by40 opinions
- Knight-Ridder Newspapers, Inc. v. United StatesCourt of Appeals for the Eleventh Circuit · 1984
- Lucille Prussner, as of the Estate of Aileen E. Pfeifer v. United StatesCourt of Appeals for the Seventh Circuit · 1990
- Tipps v. CommissionerUnited States Tax Court · 1980
- American Air Filter Co. v. CommissionerUnited States Tax Court · 1983
- Estate of Gunland v. CommissionerUnited States Tax Court · 1987
35 more not listed; retrieve them via the Exa API.