Legal Opinion
Ruddick Corp. v. United States
United States Court of Claims
Decided February 25, 1981No. 477-77PublishedCited by 14 opinions
1Opinion of the CourtDavis, Judge
At bottom this case presents a problem in the application of Section 482 of the Internal Revenue Code, 26 U.S.C. 482 (1954) (amended 1976), giving the Treasury Department certain discretion to allocate income between related corporations, but first we must decide whether Section 482 can be and has been invoked in this court.
I. Facts
On the cross-motions for summary judgment now before us the following are the facts on which both parties now agree:1
Taxpayer Ruddick Corporation (Ruddick) is the parent (through a corporate reorganization) of R.S. Dickson and Company (RSD), a regional brokerage…
2Cases cited20 opinions
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
- National Securities Corp. v. Com'r of Internal RevenueCourt of Appeals for the Third Circuit · 1943
- Jud Plumbing & Heating, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
- Asiatic Petroleum Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1935
15 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Achiro v. CommissionerUnited States Tax Court · 1981
- Foster v. Comm'rUnited States Tax Court · 1983
- Rust Communications Group, Inc. v. United StatesUnited States Court of Claims · 1990
- Eli Lilly & Company and Subsidiaries, Cross-Appellees v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Seventh Circuit · 1988
- Eli Lilly & Co. v. CommissionerUnited States Tax Court · 1985
9 more not listed; retrieve them via the Exa API.