Suzy's Zoo's v. Commissioner
United States Tax Court
P, a corporation the stock of which is owned 84 percent by S and 16 percent by two individuals unrelated to S, sells greeting cards and other paper products bearing an image of one or more of P's licensed cartoon characters. P's employees develop and draw the originals of all of the characters, and P transfers the original drawings to independent printing companies to reproduce images of the drawings onto P's paper products, which are made by the printers on P's behalf.
Read the full summary
P, a corporation the stock of which is owned 84 percent by S and 16 percent by two individuals unrelated to S, sells greeting cards and other paper products bearing an image of one or more of P's licensed cartoon characters. P's employees develop and draw the originals of all of the characters, and P transfers the original drawings to independent printing companies to reproduce images of the drawings onto P's paper products, which are made by the printers on P's behalf. The printers must reproduce the drawings and make the products in accordance with P's specifications, and they may not sell…
1Opinion of the Court
OPINION
Laro, Judge:
This case is before the Court fully stipulated. See Rule 122. Respondent determined a $131,077 deficiency in petitioner’s Federal income tax for its taxable year ended June 30, 1994. We decide primarily whether petitioner is subject to the uniform capitalization (UNICAP) rules of section 263A. We hold it is. We also decide whether the subject year is the “year of change” for purposes of section 481. We hold it is. Unless otherwise indicated, section references are to the Internal Revenue Code applicable to the subject year, and Rule references are to the Tax Court Rules of…
2Cases cited16 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Garcia v. United StatesSupreme Court of the United States · 1985
- Schwegmann Bros. v. Calvert Distillers Corp.Supreme Court of the United States · 1951
- Dixon v. United StatesSupreme Court of the United States · 1965
- Knight-Ridder Newspapers, Inc. v. United StatesCourt of Appeals for the Eleventh Circuit · 1984
11 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- MedChem, Inc. v. Comm'rUnited States Tax Court · 2001
- ADVO, Inc. & Subsidiaries v. CommissionerUnited States Tax Court · 2013
- City Line Candy & Tobacco Corp. v. CommissionerUnited States Tax Court · 2013
- Patients Mutual Assistance Collective Corporation d.b.a. Harborside Health Center v. CommissionerUnited States Tax Court · 2018
- Patients Mutual Assistance Collective Corporation d.b.a. Harborside Health Center v. CommissionerUnited States Tax Court · 2018
13 more not listed; retrieve them via the Exa API.