Legal Opinion
SIH Partners LLLP, Explorer Partner Corporation, Tax Matters Partner v. Commissioner
United States Tax Court
Decided January 18, 2018No. 3427-15Unknown
1Opinion of the Court
150 T.C. No. 3
UNITED STATES TAX COURT SIH PARTNERS LLLP, EXPLORER PARTNER CORPORATION, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3427-15. Filed January 18, 2018. S was the U.S. shareholder of two CFCs that guaranteed loans made to a U.S. person. R determined that S must include in its gross income for the tax years in issue the CFCs’ applicable earnings pursuant to I.R.C. secs. 951(a)(1)(B) and 956(d). R’s determination relied on regulations promulgated under I.R.C. sec. 956 (regulations). R also determined that the amounts included in S’s…
2Cases cited34 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Motor Vehicle Mfrs. Assn. of United States, Inc. v. State Farm Mut. Automobile Ins. Co.Supreme Court of the United States · 1983
- Citizens to Preserve Overton Park, Inc. v. VolpeSupreme Court of the United States · 1971
- Califano v. SandersSupreme Court of the United States · 1977
- United States v. Mead Corp.Supreme Court of the United States · 2001
29 more not listed; retrieve them via the Exa API.