Casanova Co. v. Commissioner
United States Tax Court
P seeks exemption from the withholding requirements of secs. 1441 and 1442, I.R.C. 1954, based upon treaty provisions between the United States and the Netherlands and R's applicable regulation, and based upon exemption documents applicable to the period in question. R, while conceding the authenticity of the documents, contends that they are ineffective because filed late.
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P seeks exemption from the withholding requirements of secs. 1441 and 1442, I.R.C. 1954, based upon treaty provisions between the United States and the Netherlands and R's applicable regulation, and based upon exemption documents applicable to the period in question. R, while conceding the authenticity of the documents, contends that they are ineffective because filed late. Upon cross-motions for summary judgment: Held, that there are no material facts in dispute, and the case may be decided as a matter of law. Held, further: That the documents are valid to confer exemption under existing…
1Opinion of the Court
Casanova Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Casanova Co. v. Commissioner
Docket No. 25468-84
United States Tax Court
87 T.C. 214; 1986 U.S. Tax Ct. LEXIS 72; 87 T.C. No. 13;
July 28, 1986, Filed
Decision will be entered for the petitioner.
P seeks exemption from the withholding requirements of secs. 1441 and 1442, I.R.C. 1954, based upon treaty provisions between the United States and the Netherlands and R's applicable regulation, and based upon exemption documents applicable to the period in question. R, while conceding the authenticity of the documents, contends…
2Cases cited18 opinions
- Adickes v. S. H. Kress & Co.Supreme Court of the United States · 1970
- United States v. Diebold, Inc.Supreme Court of the United States · 1962
- Dixon v. United StatesSupreme Court of the United States · 1965
- Stubbs, Overbeck & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Martha Lyons v. Board of Education of Charleston Reorganized School District No. 1 of Mississippi County, MissouriCourt of Appeals for the Eighth Circuit · 1975
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