Legal Opinion
Condor International, Inc. v. Commissioner Internal Revenue Service
Court of Appeals for the Ninth Circuit
Decided March 6, 1996No. Nos. 93-70513, 93-70526PublishedCited by 1 opinion
1Opinion of the Court
LEAVY, Circuit Judge:
In this case we are called upon to review a decision of the United States Tax Court (“Tax Court”) upholding the government’s assessment of various taxes and penalties against a husband, his wife, and their Delaware holding company formerly operating in the United States Virgin Islands (“USVI”). For the reasons which follow, we affirm the imposition of capital gains taxes against the husband and wife and the Delaware company, but reverse the assessed deficiencies.
FACTS AND PRIOR PROCEEDINGS
In 1958, James E. Welsh (‘Welsh”) founded Arlon Products, Inc. (“Arlon”), a…
2Cases cited7 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- United States v. BoyleSupreme Court of the United States · 1985
- Danbury, Inc. v. Anthony Olive, Director, Bureau of Internal Revenue, Government of the Virgin IslandsCourt of Appeals for the Third Circuit · 1987
- Condor Int'l v. CommissionerUnited States Tax Court · 1992
- Vernon L. Correia Charlotte M. Correia v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1995
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3Cited by1 opinion
- Condor International, Inc., N.K.A. Applied Resources, Inc. v. Commissioner Internal Revenue Service, Condor International, Inc., N.K.A. Applied Resources, Inc. James E. Welsh Nancy S. Welsh, Petitioners-Appellants/cross-Appellees v. Commissioner Internal Revenue Service, Respondent-Appellee/cross-AppellantCourt of Appeals for the Ninth Circuit · 1996