Globe Products Corp. v. Commissioner
United States Tax Court
T, an accrual basis taxpayer, is a former member of an affiliated group of corporations that filed consolidated returns. In 1968, T and several other former affiliates entered into an agreement (sharing agreement) to share payment of potential Federal income tax liabilities and interest that might subsequently be determined to be owed by the affiliated group for earlier consolidated return years.
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T, an accrual basis taxpayer, is a former member of an affiliated group of corporations that filed consolidated returns. In 1968, T and several other former affiliates entered into an agreement (sharing agreement) to share payment of potential Federal income tax liabilities and interest that might subsequently be determined to be owed by the affiliated group for earlier consolidated return years. On Aug. 1, 1972, a stipulated decision was entered by this Court finding deficiencies in Federal consolidated income tax for 1961 and 1962 against the affiliated group. Pursuant to the sharing…
1Opinion of the Court
OPINION
Raum, Judge:
The Commissioner determined a deficiency in petitioner’s 1972 Federal income tax in the amount of $78,750 and an addition to tax under section 6651(a), I.R.C. 1954, in the amount of $3,938. Petitioner is a former member of an affiliated group of corporations that filed consolidated returns. After concessions, the only issue presented is whether petitioner, an accrual basis taxpayer, may deduct in the year at issue any part of its liability under an agreement with other former affiliates to share payment of Federal income taxes and interest owed in respect of earlier…
2Cases cited17 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- Helvering v. Russian Finance & Construction CorporationCourt of Appeals for the Second Circuit · 1935
- Baltimore Transfer Co. v. CommissionerUnited States Tax Court · 1947
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3Cited by5 opinions
- Abraham v. United StatesDistrict Court, S.D. New York · 1984
- Estate of Blazzard v. Comm'rUnited States Tax Court · 1991
- Globe Products Corp. v. CommissionerUnited States Tax Court · 1979
- Merit Tank & Body, Inc. v. CommissionerUnited States Tax Court · 1980
- Utah Power & Light Co. & Subsidiary v. CommissionerUnited States Tax Court · 1991