Brown Group v. Commissioner
United States Tax Court
Petitioner is the common parent corporation of an affiliated group of corporations making a consolidated return of income (the affiliated group). The only issue in dispute is whether a member of the affiliated group's share of partnership income from a foreign partnership is subpt. F income, includable in the gross income of the member under sec. 951(a), I.R.C.Held, such income is subpt. F income includable in the gross income of the member under sec. 951(a), I.R.C.
1Opinion of the Court
Brown Group, Inc. and Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent *
Brown Group v. Commissioner
Docket No. 104-92
United States Tax Court
104 T.C. 105; 1995 U.S. Tax Ct. LEXIS 5; 104 T.C. No. 5;
January 25, 1995, Filed
Decision will be entered for respondent.
Petitioner is the common parent corporation of an affiliated group of corporations making a consolidated return of income (the affiliated group). The only issue in dispute is whether a member of the affiliated group's share of partnership income from a foreign partnership is subpt. F income, includable in the gross…
Also in this document: Concurrence · Ruwe; Concurrence · Beghe; Concurrence · Chiechi; Dissent.
2Cases cited40 opinions
- Bull v. United StatesSupreme Court of the United States · 1935
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
- Brannen v. CommissionerUnited States Tax Court · 1982
- United States v. BasyeSupreme Court of the United States · 1973
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
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