Legal Opinion

MedChem, Inc. v. Comm'r

United States Tax Court

Decided May 18, 2001No. 4065-98; No. 4066-98PublishedCited by 12 opinions

P-USA is a corporation that is headquartered and has its manufacturing facility in the United States. Its wholly owned subsidiary is P-PR, which lists as its headquarters, officers, and directors the headquarters, officers, and directors of P- USA. A is a corporation unrelated to Ps that manufactures in Puerto Rico a drug named Avitene.

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P-USA is a corporation that is headquartered and has its manufacturing facility in the United States. Its wholly owned subsidiary is P-PR, which lists as its headquarters, officers, and directors the headquarters, officers, and directors of P- USA. A is a corporation unrelated to Ps that manufactures in Puerto Rico a drug named Avitene. On Dec. 18, 1987, A and certain related entities sold to Ps the equipment, technology, and other assets (except A's manufacturing facility in Puerto Rico) connected to Avitene's manufacturing. As part of the sale, A agreed to continue manufacturing Avitene…

1Opinion of the Court

OPINION

Laro, Judge:

These consolidated cases were submitted to the Court without trial. See Rule 122. Respondent determined an $815,196 deficiency in the Federal income tax of MedChem (P.R.), Inc. (MedChem P.R.), for its taxable year ended August 31, 1992. Respondent determined a $1,705,019 deficiency in the Federal income tax of MedChem Products, Inc., & Subsidiaries (MedChem Group) for its taxable year ended August 31, 1992. Following concessions, we must decide whether MedChem P.R. meets the “active conduct of a trade or business within a possession” requirement of section 936(a)(2)(B). We…

2Cases cited21 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  3. Nationwide Mutual Insurance v. DardenSupreme Court of the United States · 1992
  4. United States v. SilkSupreme Court of the United States · 1947
  5. Higgins v. CommissionerSupreme Court of the United States · 1941

16 more not listed; retrieve them via the Exa API.

3Cited by12 opinions

  1. Elec. Arts, Inc. v. Comm'rUnited States Tax Court · 2002
  2. Beech Trucking Co. v. Comm'rUnited States Tax Court · 2002
  3. Medchem (P.R.), Inc. v. CommissionerCourt of Appeals for the First Circuit · 2002
  4. ADVO, Inc. & Subsidiaries v. CommissionerUnited States Tax Court · 2013
  5. Advo, Inc. & Subsidiaries v. CommissionerUnited States Tax Court · 2013

7 more not listed; retrieve them via the Exa API.

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