Legal Opinion
American Air Liquide, Inc. and Subsidiaries v. Commissioner
United States Tax Court
Decided January 16, 2001No. 20381-98Unknown
1Opinion of the Court
116 T.C. No. 3
UNITED STATES TAX COURT AMERICAN AIR LIQUIDE, INC. AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20381-98. Filed January 16, 2001. P is the parent of a consolidated group that includes L. P’s ultimate parent is L’Air, a French corporation. L’Air pays royalties to P and L under license agreements for intellectual property owned by P and L and used by L’Air outside the United States. P treated the royalty income as sec. 904(d)(1)(I), I.R.C., general limitation income, relying on the “reserved” paragraph in sec. 1.904-5(i)(3), Income Tax…
2Cases cited20 opinions
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Naftel v. CommissionerUnited States Tax Court · 1985
- Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
- Whitney v. RobertsonSupreme Court of the United States · 1888
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