Brown Group v. Commissioner
United States Tax Court
Petitioner is the common parent corporation of an affiliated group of corporations making a consolidated return of income (the affiliated group). The only issue in dispute is whether a member of the affiliated group's share of partnership income from a foreign partnership is subpt. F income, includable in the gross income of the member under sec. 951(a), I.R.C.Held, such income is subpt. F income includable in the gross income of the member under sec. 951(a), I.R.C.
1Opinion of the Court
Halpern, Judge:
Petitioner is the common parent corporation of an affiliated group of corporations making a consolidated return of income (the affiliated group). Respondent determined a deficiency of $388,992.85 in the income tax liability of the affiliated group for its taxable year ended November 1, 1986.1
The only issue in dispute is whether Brown Cayman, Ltd.’s (Brown Cayman’s) share of partnership income from Brinco, a Cayman Islands partnership, is subpart F income, includable in the gross income of a member of the affiliated group under section 951(a). We hold that it is.
Unless otherwise…
2Cases cited17 opinions
- United States v. BasyeSupreme Court of the United States · 1973
- Madison Gas and Electric Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1980
- Madison Gas & Electric Co. v. CommissionerUnited States Tax Court · 1979
- Goodwin v. CommissionerUnited States Tax Court · 1980
- Fort Howard Corp. v. CommissionerUnited States Tax Court · 1994
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3Cited by8 opinions
- Coggin Automotive Corporation v. Comr. of IRSCourt of Appeals for the Eleventh Circuit · 2002
- P.D.B. Sports v. CommissionerUnited States Tax Court · 1997
- Coggin Auto. Corp. v. CommissionerUnited States Tax Court · 2000
- Brown Group v. CommissionerUnited States Tax Court · 1995
- Coggin Auto. Corp. v. CommissionerUnited States Tax Court · 2000
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