Legal Opinion

Stanford v. Commissioner

United States Tax Court

Decided April 29, 1997No. Docket No. 103-94PublishedCited by 13 opinions

Held: For 1990, (1) subpart F income of a controlled foreign corporation may not be reduced by deficits in earnings and profits of a controlled foreign sister corporation; and (2) on the particular facts of this case, subpart F income of a controlled foreign corporation may not be reduced by deficits in earnings and profits of a controlled foreign parent corporation.

1Opinion of the Court

Swift, Judge:

Respondent determined a deficiency in, an addition to tax on, and an accuracy-related penalty on petitioners’ 1990 joint Federal income tax as follows:

Addition to tax Accuracy-related penalty Deficiency sec. 6651(a)(1) sec. 6662(a)

$423,531 $101,585 $84,706

Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 1990, and all Rule references are to the Tax Court Rules of Practice and Procedure. All references to petitioner are to Robert A. Stanford.

The issues for decision are whether subpart F income of a controlled foreign corporation may…

2Cases cited3 opinions

  1. National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
  2. Commissioner v. BollingerSupreme Court of the United States · 1988
  3. Victor D. Denenburg and Wife, Sandra J. Denenburg v. United StatesCourt of Appeals for the Fifth Circuit · 1991

3Cited by13 opinions

  1. Stanford v. CommissionerCourt of Appeals for the Fifth Circuit · 1998
  2. Aston v. Comm'rUnited States Tax Court · 1997
  3. Whitehouse Hotel Ltd. P'ship v. Comm'rUnited States Tax Court · 2012
  4. Aston v. Comm'rUnited States Tax Court · 1997
  5. Carter v. Comm'rUnited States Tax Court · 2010

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