Guardian Industries Corp. v. Commissioner

143 T.C. No. 1

UNITED STATES TAX COURT GUARDIAN INDUSTRIES CORP., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20755-12. Filed July 17, 2014. I.R.C. section 162(f) denies a deduction for “any fine or similar penalty paid to a government for the violation of any law.” Section 1.162-21(a), Income Tax Regs., provides that the term “government” includes a “corporation or other entity serving as an agency or instrumentality” of a domestic or foreign government. In 2008 P, a U.S. corporation, paid a fine to the Commission of the European Community (Commission) for…