Condor Int'l v. Commissioner
United States Tax Court
During 1984, C was an investment company incorporated under the laws of Delaware. C's principal place of business was located in the United States Virgin Islands (USVI). C never engaged in a trade or business, owned equipment, or rented office space in the USVI. C maintained a mailing address in the USVI and a certificate of deposit and checking account in a USVI bank. C's records were located at its director's office in the USVI.
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During 1984, C was an investment company incorporated under the laws of Delaware. C's principal place of business was located in the United States Virgin Islands (USVI). C never engaged in a trade or business, owned equipment, or rented office space in the USVI. C maintained a mailing address in the USVI and a certificate of deposit and checking account in a USVI bank. C's records were located at its director's office in the USVI. Annual meetings of the shareholders and the director were held in the USVI. With the exception of interest on the certificate of deposit, C's entire income was from…
1Opinion of the Court
WELLS, Judge:
In the instant consolidated proceedings (the instant case) respondent determined the following deficiencies in and additions to petitioners' Federal income tax:
Condor International, Inc.
_Additions to tax_
Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6661(a)(1) 6653(a)(1) 6653(a)(2) 6655 6661(a)
1984 $1,462,800.62 $365,720.16 $73,144.03 1 $78,218.87 $365,720.16
James E. Welsh and Nancy S. Welsh
_Additions to tax_
Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1) 6653(a)(2) 6661(a)
1983 $808,659 $201,461 $41,096 1 $202,165
Unless otherwise noted, all section references are to the…
2Cases cited23 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- United States v. BoyleSupreme Court of the United States · 1985
- Neely v. CommissionerUnited States Tax Court · 1985
- Higgins v. SmithSupreme Court of the United States · 1940
18 more not listed; retrieve them via the Exa API.
3Cited by31 opinions
- Allen v. Comm'rUnited States Tax Court · 2002
- Redlark v. Comm'rUnited States Tax Court · 1996
- Risman v. CommissionerUnited States Tax Court · 1993
- Appleton v. Comm'rUnited States Tax Court · 2013
- Farmer v. CommissionerUnited States Tax Court · 1994
26 more not listed; retrieve them via the Exa API.