Legal Opinion
F. W. Woolworth Co. v. Bureau of Revenue
New Mexico Court of Appeals
Decided December 4, 1979No. 3954PublishedCited by 5 opinions
1Opinion of the Court
OPINION
WALTERS, Judge.
The Taxation and Revenue Department assessed additional corporate income taxes for taxpayer’s fiscal 1976-77 year, and the taxpayer appeals. Woolworth contends that the Department’s inclusion in Woolworth’s base income of dividends paid to the parent company by foreign subsidiaries and foreign dividend “gross-up” amounts was unauthorized under New Mexico tax statutes. Those amounts, it says, do not constitute taxable business income under § 7-4-2 A, N.M.S.A. 1978, and are not apportionable under the Uniform Division of Income for Tax Purposes Act, “UDITPA” (§ 7-4-1…
2Cases cited8 opinions
- Hoeper v. Tax Comm'n of Wis.Supreme Court of the United States · 1931
- McEwen v. Ortho Pharmaceutical CorporationOregon Supreme Court · 1974
- McVean & Barlow, Inc. v. New Mexico Bureau of RevenueNew Mexico Court of Appeals · 1975
- Sperry and Hutchinson Co. v. Department of RevenueOregon Supreme Court · 1974
- Champion International Corp. v. Bureau of RevenueNew Mexico Court of Appeals · 1975
3 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- FW Woolworth Co. v. Taxation and Revenue Dept. of NMSupreme Court of the United States · 1982
- Taxation & Revenue Department v. F. W. Woolworth Co.New Mexico Supreme Court · 1981
- Sutin, Thayer & Browne v. Revenue Division of the Taxation & Revenue DepartmentNew Mexico Court of Appeals · 1984
- FW Woolworth Co. v. Taxation and Revenue Dept. of NMSupreme Court of the United States · 1982
- TAXATION & REVENUE DEPT., ETC. v. FW WoolworthNew Mexico Supreme Court · 1981