Legal Opinion
Addison International, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided November 6, 1989No. 89-1003PublishedCited by 17 opinions
1Opinion of the Court
BOYCE F. MARTIN, Jr., Circuit Judge.
Addison International appeals the tax court’s two-part decision in Addison International, Inc. v. Commissioner, 90 T.C. 1207 (1988), holding (1) that Addison International failed to qualify as a Domestic International Sales Corporation under §§ 991-997 of the Internal Revenue Code (1954) for the taxable year of 1977, and (2) that Addison International was the proper taxpayer with respect to current income earned for the taxable year of 1977. We affirm the tax court on both issues.
We review do novo the legal standard applied by the tax court in determining…
2Cases cited8 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- James L. Rose and Judy S. Rose v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1989
- Cwt Farms, Inc. And Cwt International, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
- Lecroy Research Systems Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1984
- Gehl Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
3 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Dixson Int'l Service Corp. v. CommissionerUnited States Tax Court · 1990
- Summa Holdings v. Comm'r of Internal RevenueCourt of Appeals for the Sixth Circuit · 2017
- L & F International Sales Corporation v. United StatesCourt of Appeals for the Ninth Circuit · 1990
- Sim-Air, USA, Ltd. v. CommissionerUnited States Tax Court · 1992
- Hellweg v. Comm'rUnited States Tax Court · 2011
12 more not listed; retrieve them via the Exa API.