Ashland Oil, Inc. v. Commissioner
United States Tax Court
DA, a Liberian corporation, is a controlled foreign corporation under sec. 957(a), I.R.C. 1954. A Belgian corporation, T, entered into a written agreement with DA, under the terms of which T manufactures chemical products for DA. DA and its affiliates own no stock or other interest, directly or indirectly, in T. T and its affiliates own no stock or other interest, directly or indirectly, in DA or its affiliates.
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DA, a Liberian corporation, is a controlled foreign corporation under sec. 957(a), I.R.C. 1954. A Belgian corporation, T, entered into a written agreement with DA, under the terms of which T manufactures chemical products for DA. DA and its affiliates own no stock or other interest, directly or indirectly, in T. T and its affiliates own no stock or other interest, directly or indirectly, in DA or its affiliates. DA and T are therefore not related persons under sec. 954(d)(3), I.R.C.Held, T is not a "branch or similar establishment" for purposes of determining the foreign base company sales…
1Opinion of the Court
OPINION
NlMS, Chief Judge:
This case is before the Court on petitioners’ motion for summary judgment under Rule 121. (Rule references are to the Tax Court Rules of Practice and Procedure. Unless otherwise noted, section references are to the Internal Revenue Code of 1954 as amended and in effect for the years at issue.)
Petitioner Ashland Oil, Inc., a domestic corporation with its principal office in Ashland, Kentucky, is the parent company of petitioner Ashland Technology, Inc., a domestic corporation with its principal office in Atlanta, Georgia. Respondent determined deficiencies in the…
2Cases cited10 opinions
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Stark v. CommissionerUnited States Tax Court · 1986
- Sims v. United StatesSupreme Court of the United States · 1959
- First Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1963
- South Jersey Sand Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1959
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