Hitachi Sales Corp. v. Commissioner
United States Tax Court
Respondent filed, on March 2, 1992, a motion for partial summary judgment with respect to six issues, all of which are tax accounting issues. In response, petitioner in effect conceded one of those issues, objected to respondent's motion with respect to two of those issues, and filed a cross-motion for partial summary judgment with respect to the remaining three issues.
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Respondent filed, on March 2, 1992, a motion for partial summary judgment with respect to six issues, all of which are tax accounting issues. In response, petitioner in effect conceded one of those issues, objected to respondent's motion with respect to two of those issues, and filed a cross-motion for partial summary judgment with respect to the remaining three issues. By order dated August 3, 1992, we considered and decided respondent's motion with respect to two issues (including the in-effect-conceded issue). Here, we consider and decide both respondent's motion with respect to the other…
1Opinion of the Court
HITACHI SALES CORPORATION OF AMERICA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hitachi Sales Corp. v. Commissioner
Docket No. 21663-90
United States Tax Court
T.C. Memo 1992-504; 1992 Tax Ct. Memo LEXIS 536; 64 T.C.M. (CCH) 634;
September 3, 1992, Filed
Respondent filed, on March 2, 1992, a motion for partial summary judgment with respect to six issues, all of which are tax accounting issues. In response, petitioner in effect conceded one of those issues, objected to respondent's motion with respect to two of those issues, and filed a cross-motion for partial summary judgment with…
2Cases cited24 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- Espinoza v. CommissionerUnited States Tax Court · 1982
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