Intel Corp. v. Commissioner
United States Tax Court
P is a corporation engaged in the design, manufacture, and sale of semiconductor components and computer systems. P DISC operated as a commission domestic international sales corporation (DISC) within the meaning of sec. 992(a)(1), I.R.C., for which P was a related supplier within the meaning of sec. 1.994-1(a)(3)(ii), Income Tax Regs., during the years at issue. P paid P DISC commissions on some of P's sales that qualified for DISC treatment.
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P is a corporation engaged in the design, manufacture, and sale of semiconductor components and computer systems. P DISC operated as a commission domestic international sales corporation (DISC) within the meaning of sec. 992(a)(1), I.R.C., for which P was a related supplier within the meaning of sec. 1.994-1(a)(3)(ii), Income Tax Regs., during the years at issue. P paid P DISC commissions on some of P's sales that qualified for DISC treatment. Portions of the commissions paid to P DISC were calculated using the "combined taxable income" method of sec. 994(a)(2), I.R.C. When computing combined…
1Opinion of the Court
OPINION
Clapp, Judge:
This case is before us on the parties’ cross-motions for partial summary judgment.
All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Respondent determined the following deficiencies in petitioner’s Federal income taxes:
Year Deficiency
1978 . $4,660,900
1979 . 6,539,152
1980 . 24,676,625
Procedural Background
This case commenced with the filing of the petition on September 19, 1989. The parties filed a partial settlement stipulation on May 16, 1990. By motion filed…
2Cases cited14 opinions
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- United States v. LarionoffSupreme Court of the United States · 1977
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
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3Cited by18 opinions
- General Dynamics Corp. v. CommissionerUnited States Tax Court · 1997
- Coca-Cola Co. v. CommissionerUnited States Tax Court · 1996
- Phillips Petroleum Co. v. CommissionerUnited States Tax Court · 1993
- UNION CARBIDE CORP. v. COMMISSIONERUnited States Tax Court · 1998
- Intel Corp. & Consol. Subsidiaries v. CommissionerUnited States Tax Court · 1998
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