Perkin-Elmer Corp. v. Commissioner
United States Tax Court
R allocated P's research and development expenses in accordance with the sales method set forth in sec. 1.861-8(e)(3)(ii), Income Tax Regs.
Read the full summary
R allocated P's research and development expenses in accordance with the sales method set forth in sec. 1.861-8(e)(3)(ii), Income Tax Regs. P asserts that the regulation is invalid because the sales method fails to take into account the research and development expenses of P's foreign subsidiaries and results in an overallocation of such expenses to such subsidiaries, thereby reducing P's foreign tax credit under secs. 901 and 904, I.R.C., exposing P to double taxation, and failing to achieve the objective of the foreign tax credit. P submits that its "worldwide" method of allocation of…
1Opinion of the Court
The Perkin-Elmer Corporation and Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent
Perkin-Elmer Corp. v. Commissioner
Docket No. 28860-89
United States Tax Court
103 T.C. 464; 1994 U.S. Tax Ct. LEXIS 69; 103 T.C. No. 26;
September 28, 1994, Filed
Decision will be entered under Rule 155.
R allocated P's research and development expenses in accordance with the sales method set forth in sec. 1.861-8(e)(3)(ii), Income Tax Regs. P asserts that the regulation is invalid because the sales method fails to take into account the research and development expenses of P's foreign…
2Cases cited19 opinions
- United States v. CorrellSupreme Court of the United States · 1967
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- United States v. Vogel Fertilizer Co.Supreme Court of the United States · 1982
- Rowan Cos. v. United StatesSupreme Court of the United States · 1981
- Lykes v. United StatesSupreme Court of the United States · 1952
14 more not listed; retrieve them via the Exa API.