Legal Opinion
Likins-Foster Honolulu Corp. v. Commissioner Nternal Revenue Service
Court of Appeals for the Ninth Circuit
Decided February 17, 1988No. 87-7001PublishedCited by 1 opinion
1Opinion of the Court
GOODWIN, Circuit Judge:
Taxpayers appeal from a decision of the United States Tax Court, 50 T.C.M. (CCH) 1465 (1985), upholding the Commissioner’s allocation, under I.R.C. § 482 (1984), of interest income to Likins-Foster, parent corporation, as a result of interest-free loans made by it to its subsidiary. We affirm.
Likins-Foster Honolulu Corporation, a cash basis taxpayer, is the common parent of an affiliated group of corporations that filed consolidated returns for the tax years ending June 30, 1961, and June 30, 1963 through June 30, 1967.
During its 1963, 1964, 1965, and 1967 fiscal years,…
2Cases cited29 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Dixon v. United StatesSupreme Court of the United States · 1965
- Burnet v. LoganSupreme Court of the United States · 1931
- Central Illinois Public Service Co. v. United StatesSupreme Court of the United States · 1978
- Russell Redhouse, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
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3Cited by1 opinion
- Likins-Foster Honolulu Corp. v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988