Legal Opinion
Advance International, Inc. v. Commissioner
United States Tax Court
Decided September 6, 1988No. Docket Nos. 7749-87, 7750-87PublishedCited by 4 opinions
Held, amounts transferred by DISC to its parent treated as actual distributions.
1Opinion of the Court
WHITAKER, Judge:
Respondent issued statutory notices of deficiencies to petitioners1 Advance Machine Co. (Machine) and Advance International, Inc. (International), on December 29, 1986. In the statutory notices respondent determined that International did not qualify as a domestic international sales corporation (DISC) during its fiscal years 1980, 1981, and 1982. Respondent determined the following deficiencies (which result from taxing International’s DISC income to both entities in the alternative):
Machine
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International
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The parties have since stipulated that…
2Cases cited8 opinions
- Cwt Farms, Inc. And Cwt International, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
- Haber v. CommissionerUnited States Tax Court · 1969
- Jack Haber and Doris Haber v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1970
- CWT Farms, Inc. v. CommissionerUnited States Tax Court · 1982
- Pierce v. CommissionerUnited States Tax Court · 1974
3 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- McCoy Enterprises, Inc., & Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1995
- General Elec. Co. v. CommissionerUnited States Tax Court · 1995
- McCoy Enters. v. CommissionerUnited States Tax Court · 1992
- Advance International, Inc. v. CommissionerUnited States Tax Court · 1988