Long v. Commissioner
United States Tax Court
Held: Respondent entered into a closing agreement with petitioner and his two controlled corporations, Manufacturing and Specialty, whereby income was allocated to Manufacturing from Specialty pursuant to sec. 482. Petitioner and the corporations elected the relief available under Rev. Proc. 65-17, 1965-1 C.B. 833. Pursuant to that election, Manufacturing and Specialty set up an account receivable and an account payable, respectively, in an amount equal to the sec. 482…
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Held: Respondent entered into a closing agreement with petitioner and his two controlled corporations, Manufacturing and Specialty, whereby income was allocated to Manufacturing from Specialty pursuant to sec. 482. Petitioner and the corporations elected the relief available under Rev. Proc. 65-17, 1965-1 C.B. 833. Pursuant to that election, Manufacturing and Specialty set up an account receivable and an account payable, respectively, in an amount equal to the sec. 482 allocation. Pursuant to the closing agreement, the account receivable was to be satisfied within 90 days after the…
1Opinion of the Court
OPINION
WHITAKER, Judge:
By statutory notice dated August 14, 1987, respondent determined a deficiency in petitioner’s 1981 Federal income tax in the amount of $139,981.41. The issues before us are whether the terms of a closing agreement with respect to certain section 4821 adjustments between corporations controlled by petitioner have been complied with, and if not, the consequences of such failure.
This case was submitted pursuant to Rule 122, the parties having stipulated all facts. The stipulation and attached exhibits are incorporated by this reference. At the time his petition was filed,…
2Cases cited10 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Richard Rubin and Helene Rubin v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970
- United States v. LaneCourt of Appeals for the Fifth Circuit · 1962
- Paccar, Inc. And Subsidiaries v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
- Bausch & Lomb, Inc. v. CommissionerUnited States Tax Court · 1989
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3Cited by6 opinions
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- Long v. CommissionerUnited States Tax Court · 1989
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