FMC Corp. v. Commissioner
United States Tax Court
With regard to the domestic international sales corporation (DISC) provisions of the Internal Revenue Code, held: (1) Industrial cranes used on oil drilling platforms attached to the Outer Continental Shelf of the United States in the Gulf of Mexico were not used "outside the United States"; (2) In calculating deemed distributions under sec. 995, I.R.C., FMC Corp. (petitioner) is required to aggregate base period export receipts of a DISC that petitioner acquired in 1976…
Read the full summary
With regard to the domestic international sales corporation (DISC) provisions of the Internal Revenue Code, held: (1) Industrial cranes used on oil drilling platforms attached to the Outer Continental Shelf of the United States in the Gulf of Mexico were not used "outside the United States"; (2) In calculating deemed distributions under sec. 995, I.R.C., FMC Corp. (petitioner) is required to aggregate base period export receipts of a DISC that petitioner acquired in 1976 with the base period export receipts of other DISC's that petitioner owned; (3) In calculating deemed distributions under…
1Opinion of the Court
FMC CORPORATION AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
FMC Corp. v. Commissioner
Docket Nos. 2016-90, 20609-90
United States Tax Court
100 T.C. 595; 1993 U.S. Tax Ct. LEXIS 39; 100 T.C. No. 38;
June 24, 1993, Filed
Decisions will be entered under Rule 155.
With regard to the domestic international sales corporation (DISC) provisions of the Internal Revenue Code, held:(1) Industrial cranes used on oil drilling platforms attached to the Outer Continental Shelf of the United States in the Gulf of Mexico were not used "outside the United States";(2) In calculating…
2Cases cited12 opinions
- United States v. Vogel Fertilizer Co.Supreme Court of the United States · 1982
- Patricia A. Price v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1989
- Bolton v. CommissionerUnited States Tax Court · 1981
- Heppner v. Alyeska Pipeline Service Co.Court of Appeals for the Ninth Circuit · 1981
- Dorance D. And Helen A. Bolton v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
7 more not listed; retrieve them via the Exa API.