Edwards v. Commissioner
United States Tax Court
Pursuant to sec. 482, respondent allocated income to a partnership in respect of sales of equipment by the partnership to a commonly controlled corporation. Respondent's allocation was based upon a determination that an arm's-length price for such equipment would be equal to the manufacturer's list price.
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Pursuant to sec. 482, respondent allocated income to a partnership in respect of sales of equipment by the partnership to a commonly controlled corporation. Respondent's allocation was based upon a determination that an arm's-length price for such equipment would be equal to the manufacturer's list price. Respondent also disallowed a portion of the depreciation claimed by the corporation with respect to equipment used by it in its business. 1. Held, respondent's determination of arm's-length price was unreasonable and arbitrary. 2. Held, further, arm's-length price determined by reference to…
1Opinion of the Court
Irwin, Judge:
Respondent determined the following deficiencies and overassessment in petitioners’ Federal income taxes:
Taxable year ended Deficiency Overassessment
Edward K. and Helen Edwards. 12/31/68 $928.18
12/31/69 $10,660.02
12/31/70 15,788.88
Tex Edwards Co., Inc., 5/31/69 11,572.42
5/31/70 25,416.72
The issues remaining for our determination are: (1) Whether respondent properly "allocated” income, pursuant to section 482,1 in respect of sales of equipment by a partnership to a corporation, both of which were controlled by the individual petitioners; and (2) the correct amount of depreciation…
2Cases cited19 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
- Ach v. CommissionerUnited States Tax Court · 1964
- Hertz Corp. v. United StatesSupreme Court of the United States · 1960
14 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Foster v. Comm'rUnited States Tax Court · 1983
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1991
- Bausch & Lomb, Inc. v. CommissionerUnited States Tax Court · 1989
- Seagate Technology v. CommissionerUnited States Tax Court · 1994
- E. I. du Pont de Nemours & Co. v. United StatesUnited States Court of Claims · 1979
17 more not listed; retrieve them via the Exa API.