TG Mo. Corp. v. Comm'r
United States Tax Court
P develops and uses production molds to manufacture automotive parts for its customers. P contracts with third-party toolmakers to build the production molds that P does not construct. After a third-party toolmaker finishes constructing a production mold, P purchases the mold and incurs additional design and engineering costs to modify the mold so that it can be used to produce the desired component part.
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P develops and uses production molds to manufacture automotive parts for its customers. P contracts with third-party toolmakers to build the production molds that P does not construct. After a third-party toolmaker finishes constructing a production mold, P purchases the mold and incurs additional design and engineering costs to modify the mold so that it can be used to produce the desired component part. P then either sells the completed production molds to its customers or retains ownership of the molds, but in either case P keeps the molds for production of automotive parts. On its 1998…
1Opinion of the Court
TG MISSOURI CORPORATION F.K.A. TG (U.S.A.) CORPORATION, A MISSOURI CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
TG Mo. Corp. v. Comm'r
No. 8333-06
United States Tax Court
133 T.C. 278; 2009 U.S. Tax Ct. LEXIS 33; 133 T.C. No. 13;
November 12, 2009, Filed
P develops and uses production molds to manufacture automotive parts for its customers. P contracts with third-party toolmakers to build the production molds that P does not construct. After a third-party toolmaker finishes constructing a production mold, P purchases the mold and incurs additional design and engineering…
2Cases cited28 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Robinson v. Shell Oil Co.Supreme Court of the United States · 1997
- Food & Drug Administration v. Brown & Williamson Tobacco Corp.Supreme Court of the United States · 2000
- United States v. JanisSupreme Court of the United States · 1976
- Gustafson v. Alloyd Co.Supreme Court of the United States · 1995
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