Legal Opinion
Lecroy Research Systems Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided December 20, 1984No. 55, Docket 84-4062PublishedCited by 58 opinions
1Opinion of the Court
WINTER, Circuit Judge:
LeCroy Research Systems Corporation (“LeCroy”) appeals from the decision of the United States Tax Court disqualifying its wholly owned subsidiary LRS Export Corporation (“LRS”) as a Domestic International Sales Corporation (“DISC”) because commissions owed by LeCroy to LRS were not paid within sixty days of the close of LRS’s tax year and thus were not “qualified export assets.” The Tax Court affirmed the Commissioner’s assessment of a deficiency against LeCroy of $84,858 for LeCroy’s tax year ending June 30, 1975. Because we believe the retroactive application of…
2Cases cited9 opinions
- Dixon v. United StatesSupreme Court of the United States · 1965
- Anderson, Clayton & Co., Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1977
- CWT Farms, Inc. v. CommissionerUnited States Tax Court · 1982
- Elkins v. CommissionerUnited States Tax Court · 1983
- Irving A. Adler v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1964
4 more not listed; retrieve them via the Exa API.
3Cited by58 opinions
- Sweet v. SheahanCourt of Appeals for the Second Circuit · 2000
- E. Norman Peterson Marital Trust, Chemical Bank, Trustee v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1996
- Cwt Farms, Inc. And Cwt International, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
- Zinniel v. CommissionerUnited States Tax Court · 1987
- Dresser Industries, Inc. And Consolidated Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
53 more not listed; retrieve them via the Exa API.