Condor Int'l v. Commissioner
United States Tax Court
During 1984, C was an investment company incorporated under the laws of Delaware. C's principal place of business was located in the United States Virgin Islands (USVI). C never engaged in a trade or business, owned equipment, or rented office space in the USVI. C maintained a mailing address in the USVI and a certificate of deposit and checking account in a USVI bank. C's records were located at its director's office in the USVI.
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During 1984, C was an investment company incorporated under the laws of Delaware. C's principal place of business was located in the United States Virgin Islands (USVI). C never engaged in a trade or business, owned equipment, or rented office space in the USVI. C maintained a mailing address in the USVI and a certificate of deposit and checking account in a USVI bank. C's records were located at its director's office in the USVI. Annual meetings of the shareholders and the director were held in the USVI. With the exception of interest on the certificate of deposit, C's entire income was from…
1Opinion of the Court
Condor International, Inc., n.k.a. Applied Resources, Inc., Petitioner 1 v. Commissioner of Internal Revenue, Respondent; James E. Welsh and Nancy S. Welsh, Petitioners v. Commissioner of Internal Revenue, Respondent
Condor Int'l v. Commissioner
Docket Nos. 37194-87, 39983-87
United States Tax Court
98 T.C. 203; 1992 U.S. Tax Ct. LEXIS 19; 98 T.C. No. 16;
February 26, 1992, Filed
Decisions will be entered under Rule 155.
During 1984, C was an investment company incorporated under the laws of Delaware. C's principal place of business was located in the United States Virgin Islands (USVI). C never…
2Cases cited25 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- United States v. BoyleSupreme Court of the United States · 1985
- Neely v. CommissionerUnited States Tax Court · 1985
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