Trinity Indus. v. Comm'r
United States Tax Court
Company T, a member of P's affiliated group, contracted to build barges for two established customers; pursuant to an interim financing arrangement, part of the purchase price was deferred until 18 months after the delivery of each barge.
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Company T, a member of P's affiliated group, contracted to build barges for two established customers; pursuant to an interim financing arrangement, part of the purchase price was deferred until 18 months after the delivery of each barge. The two customers later claimed damages from alleged defects in barges that they had previously purchased from T under earlier contracts; they withheld deferred payments due under the later contract, asserting common law rights to offset the deferred payments against their claimed damages under the earlier contracts. In reporting the affiliated group's 2002…
1Opinion of the Court
Thornton, Judge:
Trinity Industries, Inc. (petitioner), is the common parent of an affiliated group of corporations making a consolidated return of income (the affiliated group).1 By notice of deficiency, respondent determined a $5,900,808 deficiency for petitioner’s taxable year ending March 31, 1999.2 All but one of the adjustments that gave rise to that deficiency have been settled. The only remaining issue involves accrual of income earned by petitioner’s wholly owned subsidiary, Trinity Marine Products, Inc. (Trinity), for the taxable year ending December 31, 2002.
More particularly, in…
2Cases cited21 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Commissioner v. HansenSupreme Court of the United States · 1959
- Cal-Maine Foods, Inc. v. CommissionerUnited States Tax Court · 1989
- Marshall M. Chernin Ida Raye Chernin, Cross-Appellants/appellees v. United States of America, Appellant/cross-AppelleeCourt of Appeals for the Eighth Circuit · 1998
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3Cited by3 opinions
- Bruen v. Comm'rUnited States Tax Court · 2009
- Trinity Indus. v. Comm'rUnited States Tax Court · 2009
- Trinity Industries, Inc. and Subsidiaries v. CommissionerUnited States Tax Court · 2009