Doyle, Dane, Bernbach, Inc. v. Commissioner
United States Tax Court
Held, in order to satisfy the "all events" test of sec. 1.451-1(a), Income Tax Regs., the proper year for P, an accrual method taxpayer, to include in income refunds of New York State franchise taxes and New York City corporation taxes is the year the right to those refunds is ultimately determined.
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Held, in order to satisfy the "all events" test of sec. 1.451-1(a), Income Tax Regs., the proper year for P, an accrual method taxpayer, to include in income refunds of New York State franchise taxes and New York City corporation taxes is the year the right to those refunds is ultimately determined. Held, further: In applying sec. 862(b), I.R.C. 1954, as amended, to decide whether a deduction is allocable to foreign source income, the test is whether the expense, loss, or other deduction was incurred to derive income from such foreign source. Because the proceeds of the loan P, as guarantor,…
1Opinion of the Court
Doyle, Dane, Bernbach, Inc. (and Domestic Subsidiaries), Petitioner v. Commissioner of Internal Revenue, Respondent
Doyle, Dane, Bernbach, Inc. v. Commissioner
Docket No. 14077-78
United States Tax Court
79 T.C. 101; 1982 U.S. Tax Ct. LEXIS 63; 79 T.C. No. 6;
July 21, 1982, Filed
Decision will be entered under Rule 155.
Held, in order to satisfy the "all events" test of sec. 1.451-1(a), Income Tax Regs., the proper year for P, an accrual method taxpayer, to include in income refunds of New York State franchise taxes and New York City corporation taxes is the year the right to those refunds is…
2Cases cited11 opinions
- United States v. SanchezSupreme Court of the United States · 1950
- Theo. H. Davies & Co. v. CommissionerUnited States Tax Court · 1980
- Motors Insurance v. United StatesUnited States Court of Claims · 1976
- Royal Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1938
- Kenyon Instrument Co. v. CommissionerUnited States Tax Court · 1951
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