Dresser Industries, Inc. v. Commissioner
United States Tax Court
Held, P is not entitled to net interest income against interest expense in determining the amount of deduction to be allocated and apportioned in computing the combined taxable income (CTI) of P and its DISC under sec. 994(a)(2), I.R.C. 1954. Held, further: Sec. 1.994-1(c)(6)(v), Income Tax Regs., is valid. The CTI of P and its DISC must be reduced by the full amount of discount incurred on the sale of export accounts receivable from P to its DISC.
1Opinion of the Court
Parr, Judge:
By separate statutory notices, respondent determined deficiencies in petitioners’ Federal income tax for the years ending October 31, 1976 (1976), and October 31, 1977 (1977), in the amounts of $673,545.64 and $469,209, respectively. The parties have stipulated that these amounts were determined in error, and that the correct deficiencies for 1976 and 1977 are $672,173 and $554,043, respectively. For convenience, we refer hereinafter to petitioners in the singular.
After concessions, the issues for decision are: (1) Whether petitioner is entitled to net interest income against…
2Cases cited24 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- United States v. CorrellSupreme Court of the United States · 1967
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
19 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Dresser Industries, Inc. And Consolidated Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
- Tate & Lyle, Inc. v. CommissionerUnited States Tax Court · 1994
- Brown-Forman Corp. v. CommissionerUnited States Tax Court · 1990
- Bowater, Inc. And Subsidiaries, Formerly Known as Bowater Holdings, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1997
- St. Jude Medical v. Comm'rUnited States Tax Court · 1991
22 more not listed; retrieve them via the Exa API.