Legal Opinion

Cwt Farms, Inc. And Cwt International, Inc. v. Commissioner of Internal Revenue

Court of Appeals for the Eleventh Circuit

Decided March 19, 1985No. 84-8012PublishedCited by 95 opinions

1Opinion of the Court

HATCHETT, Circuit Judge:

In this case, we affirm the United States Tax Court’s, 79 T.C. 86, determination that CWT International, Inc. did not qualify for tax treatment as a domestic international sales corporation.

CWT Farms, Inc. (Farms) and CWT International (International) are Georgia corporations with their principal places of business in Gainesville, Georgia. Twin Oaks Hatchery, Inc. (Twin Oaks), a domestic poultry producer, organized Farms in 1958 as a sales outlet for its excess broiler chickens for export to the Caribbean and Central and South America. International is the wholly-owned…

2Cases cited25 opinions

  1. General Electric Co. v. GilbertSupreme Court of the United States · 1976
  2. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  3. Batterton v. FrancisSupreme Court of the United States · 1977
  4. United States v. CartwrightSupreme Court of the United States · 1973
  5. National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979

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3Cited by95 opinions

  1. Westbrook v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
  2. Dresser Industries, Inc. And Consolidated Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
  3. Gehl Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
  4. Eli Lilly & Company and Subsidiaries, Cross-Appellees v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Seventh Circuit · 1988
  5. ESTATE OF QUICK v. COMMISSIONERUnited States Tax Court · 1998

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