Sim-Air, USA, Ltd. v. Commissioner
United States Tax Court
P, which had previously qualified as a DISC, sold a helicopter on Dec. 31, 1983, to a related corporation which was not a DISC. On Oct. 3, 1984, the helicopter was retransferred to the U.S. seller of the helicopter, pursuant to a conditional sales contract with P's parent from whom P had acquired the helicopter in 1981. At the time of the retransfer, there was a default in the making of the payments under the conditional sales contract.
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P, which had previously qualified as a DISC, sold a helicopter on Dec. 31, 1983, to a related corporation which was not a DISC. On Oct. 3, 1984, the helicopter was retransferred to the U.S. seller of the helicopter, pursuant to a conditional sales contract with P's parent from whom P had acquired the helicopter in 1981. At the time of the retransfer, there was a default in the making of the payments under the conditional sales contract. On June 5, 1985, the seller of the helicopter to P's parent contracted to sell the helicopter and, on Oct. 21, 1985, it was delivered for export to…
1Opinion of the Court
Sim-Air, USA, Ltd., Petitioner v. Commissioner of Internal Revenue, Respondent
Sim-Air, USA, Ltd. v. Commissioner
Docket No. 5344-89
United States Tax Court
98 T.C. 187; 1992 U.S. Tax Ct. LEXIS 18; 98 T.C. No. 15;
February 24, 1992, Filed
An appropriate order will be issued.
P, which had previously qualified as a DISC, sold a helicopter on Dec. 31, 1983, to a related corporation which was not a DISC. On Oct. 3, 1984, the helicopter was retransferred to the U.S. seller of the helicopter, pursuant to a conditional sales contract with P's parent from whom P had acquired the helicopter in 1981. At the…
2Cases cited31 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Boske v. ComingoreSupreme Court of the United States · 1900
- Jackson v. CommissionerUnited States Tax Court · 1986
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