Legal Opinion
U.S. Padding Corp. v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided January 12, 1989No. 87-2211PublishedCited by 50 opinions
1Opinion of the Court
BOGGS, Circuit Judge.
The Commissioner appeals a decision of the United States Tax Court, which concluded that U.S. Padding Corp.’s (USPC’s) wholly owned subsidiary, Trans Canada Non Woven, Ltd. (Trans Canada), was incorporated in Canada for the sole purpose of complying with Canadian laws pursuant to the Foreign Investment Review Act (FIRA). Thus, Trans Canada was eligible to file a consolidated tax return with USPC pursuant to 26 U.S.C. § 1504(d). We affirm.
I
On June 19, 1981, the Commissioner determined tax deficiencies against USPC based on his determination that Trans Canada was not…
2Cases cited5 opinions
- Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Brotherhood of Railroad Trainmen v. Baltimore & Ohio RailroadSupreme Court of the United States · 1947
- U.S. Padding Corp. v. CommissionerUnited States Tax Court · 1987
- Booth Fisheries Co. v. CommissionerCourt of Appeals for the Seventh Circuit · 1936
3Cited by50 opinions
- Norfolk Southern Corp. v. CommissionerUnited States Tax Court · 1995
- Estate of Wallace v. CommissionerUnited States Tax Court · 1990
- Centel Communications Co. v. CommissionerUnited States Tax Court · 1989
- Merkel v. CommissionerUnited States Tax Court · 1997
- General Signal Corp. v. CommissionerUnited States Tax Court · 1994
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