Legal Opinion
Eaton Corporation and Subsidiaries v. Commissioner
United States Tax Court
Decided February 25, 2019No. 28040-14Unknown
1Opinion of the Court
152 T.C. No. 2
UNITED STATES TAX COURT EATON CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 28040-14. Filed February 25, 2019. This case is before us on cross-motions for partial summary judgment. The issue is whether the earnings and profits (E&P) of the upper tier controlled foreign corporation (CFC) partners of Eaton Worldwide LLC (EW LLC), a domestic partnership, must be increased as a result of the partnership’s I.R.C. sec. 951(a) income inclusions. P contends that EW LLC’s I.R.C. sec. 951(a) inclusions do not affect the E&P of its…
2Cases cited18 opinions
- Skidmore v. Swift & Co.Supreme Court of the United States · 1944
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Dodd v. United StatesSupreme Court of the United States · 2005
- Joseph R. Dileo, Mary A. Dileo, Walter E. Mycek, Jr., Michele A. Mycek and Arcelo Reproduction Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1992
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