McCoy Enters. v. Commissioner
United States Tax Court
R determined deficiencies against corporations related to a disqualified DISC, which deficiencies arose on account of such disqualification. The disqualification was precipitated by an amount shown on the DISC's tax return as "producer's loans". R determined that the item in question represented a nonqualified export asset and disqualified the DISC.
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R determined deficiencies against corporations related to a disqualified DISC, which deficiencies arose on account of such disqualification. The disqualification was precipitated by an amount shown on the DISC's tax return as "producer's loans". R determined that the item in question represented a nonqualified export asset and disqualified the DISC. Ps argue that the item in question was not an asset at all but a record of actual distributions made to the DISC's parent. 1. Held: The item in question represents a nonqualified export asset and results in the disqualification of the DISC. 2.…
1Opinion of the Court
MCCOY ENTERPRISES, INC. AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent; MCCOY ENTERPRISES, INC. AND SUBSIDIARIES, TRANSFEREE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
McCoy Enters. v. Commissioner
Docket Nos. 5626-90, 5627-90
United States Tax Court
T.C. Memo 1992-693; 1992 Tax Ct. Memo LEXIS 741; 64 T.C.M. (CCH) 1449;
December 7, 1992, Filed
Decision will be entered under Rule 155 in docket No. 5626-90.
Decision will be entered for petitioners in docket No. 5627-90.
R determined deficiencies against corporations related to a disqualified DISC, which…
2Cases cited14 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Neely v. CommissionerUnited States Tax Court · 1985
- Enoch v. CommissionerUnited States Tax Court · 1972
- American Properties, Inc. v. CommissionerUnited States Tax Court · 1957
- Pritchett v. CommissionerUnited States Tax Court · 1974
9 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- McCoy Enterprises, Inc., & Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1995