RJR Nabisco v. Commissioner
United States Tax Court
P is the common parent of an affiliated group of corporations making a consolidated return of income. M1, a member of the affiliated group, claimed a deduction pursuant to sec. 162, I.R.C., for graphic design expenditures relating to cigarette package designs. M2, another member of the affiliated group, reported a portion of an international arbitration award that it received as an amount realized on the sale or other disposition of property.
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P is the common parent of an affiliated group of corporations making a consolidated return of income. M1, a member of the affiliated group, claimed a deduction pursuant to sec. 162, I.R.C., for graphic design expenditures relating to cigarette package designs. M2, another member of the affiliated group, reported a portion of an international arbitration award that it received as an amount realized on the sale or other disposition of property. R determined a deficiency in P's consolidated income tax liability, disallowing the deduction as a sec. 162, I.R.C., expense and recharacterizing the…
1Opinion of the Court
RJR NABISCO INC. (FORMERLY R.J. REYNOLDS INDUSTRIES, INC.) AND CONSOLIDATED SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
RJR Nabisco v. Commissioner
Tax Ct. Dkt. No. 3796-95
United States Tax Court
T.C. Memo 1998-252; 1998 Tax Ct. Memo LEXIS 251; 76 T.C.M. (CCH) 71;
July 8, 1998, Filed
Decision will be entered under Rule 155.
P is the common parent of an affiliated group of corporations making a consolidated return of income. M1, a member of the affiliated group, claimed a deduction pursuant to sec. 162, I.R.C., for graphic design expenditures relating to cigarette…
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- Original Appalachian Artworks, Inc. v. Toy Loft, Inc.Court of Appeals for the Eleventh Circuit · 1982
- Kieselbach v. CommissionerSupreme Court of the United States · 1943
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