Topps of Canada, Ltd. v. Commissioner
United States Tax Court
The petitioner was engaged in selling watch bands and other similar items in Canada. Parts of such watch bands, and some of the other articles, were obtained from Hong Kong and Japan. The petitioner then further processed and assembled the watch bands and packaged the items.
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The petitioner was engaged in selling watch bands and other similar items in Canada. Parts of such watch bands, and some of the other articles, were obtained from Hong Kong and Japan. The petitioner then further processed and assembled the watch bands and packaged the items. The cost of items purchased in those places, title to which passed there, constituted more than half of the total cost of all purchases made by petitioner in the year in question, and amounted to over 34 percent of the petitioner's total gross receipts for the year. Held: That such purchases were not "incidental…
1Opinion of the Court
Atkins, Judge:
The respondent determined a deficiency in income tax for the taxable year ended July 31, 1955, in the amount of $2,925.53.
The only issue is whether during the year in question the petitioner qualified as a Western Hemisphere trade corporation within the meaning of section 921 of the Internal Kevenue Code of 1954, and is, therefore, entitled to the special deduction provided by section 922 of such Code.
FINDINGS OF FACT.
Some of the facts are stipulated and are incorporated herein by this reference.
The petitioner is a domestic corporation, organized on November 26, 1951, under the…
2Cases cited10 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Brewster v. GageSupreme Court of the United States · 1930
- Adams v. CommissionerUnited States Tax Court · 1985
- A. P. Green Export Company v. United StatesUnited States Court of Claims · 1960
- Baugh v. United StatesCourt of Appeals for the Ninth Circuit · 1928
5 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Tebon v. CommissionerUnited States Tax Court · 1970
- Tilford v. CommissionerUnited States Tax Court · 1980
- Kampel v. CommissionerUnited States Tax Court · 1979
- Commissioner of Internal Revenue v. Hammond Organ Western Export CorporationCourt of Appeals for the Seventh Circuit · 1964
- Otis Elevator Co. v. United StatesUnited States Court of Claims · 1980
6 more not listed; retrieve them via the Exa API.