Legal Opinion

Communications Satellite Corp. v. United States

United States Court of Claims

Decided April 2, 1980No. 155-78PublishedCited by 6 opinions

1Opinion of the CourtFriedman, Chief Judge

The plaintiff in this case is a member of the International Telecommunications Satellite Consortium (INTELSAT), an international joint venture (deemed a partnership for federal tax purposes) thát operates a global commercial communications satellite system. The issue is the federal tax treatment of certain monetary distributions made by INTELSAT to its members, including the plaintiff, reflecting payments by new members required for admission to the partnership. The plaintiff contends that these payments were distributions of partnership assets, which do not require recognition of gain; the…

2Cases cited2 opinions

  1. Otey v. CommissionerUnited States Tax Court · 1978
  2. John H. Otey, Jr. And Bettye G. Otey v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1980

3Cited by6 opinions

  1. Colonnade Condominium, Inc. v. CommissionerUnited States Tax Court · 1988
  2. Jupiter Corp. v. United StatesUnited States Court of Claims · 1983
  3. Jacobson v. CommissionerUnited States Tax Court · 1991
  4. Colonnade Condominium, Inc. v. CommissionerUnited States Tax Court · 1988
  5. Jacobson v. CommissionerUnited States Tax Court · 1991

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