Exolon Co. v. Commissioner
United States Board of Tax Appeals
Petitioner, a domestic corporation with its main office in this country, operates a plant in Canada. Certain contracts were executed at such main office providing for sales of material to be thereafter manufactured at its Canadian plant. Delivery was to be made and title pass to the purchaser in Canada. Payment for the goods was to be made after delivery to the purchaser and at petitioner's home office in the United States.
Read the full summary
Petitioner, a domestic corporation with its main office in this country, operates a plant in Canada. Certain contracts were executed at such main office providing for sales of material to be thereafter manufactured at its Canadian plant. Delivery was to be made and title pass to the purchaser in Canada. Payment for the goods was to be made after delivery to the purchaser and at petitioner's home office in the United States. Held, that such sales were made in Canada, within the purview of section 119(e) of the Revenue Act of 1936. East Coast Oil Co., S.A.,31 B.T.A. 558; affd., 85 Fed.(2d) 322,…
1Opinion of the Court
THE EXOLON COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Exolon Co. v. Commissioner
Docket No. 101276.
United States Board of Tax Appeals
45 B.T.A. 844; 1941 BTA LEXIS 1060;
December 2, 1941, Promulgated
Petitioner, a domestic corporation with its main office in this country, operates a plant in Canada. Certain contracts were executed at such main office providing for sales of material to be thereafter manufactured at its Canadian plant. Delivery was to be made and title pass to the purchaser in Canada. Payment for the goods was to be made after delivery to the purchaser and…
2Cases cited2 opinions
- East Coast Oil Co., S. A. v. CommissionerUnited States Board of Tax Appeals · 1934
- Exolon Co. v. CommissionerUnited States Board of Tax Appeals · 1941