Altama Delta Corp. v. Commissioner
United States Tax Court
Petitioner, ADC, manufactured combat boots. Its Puerto Rican subsidiary, ADPR, manufactured the uppers for such boots and transferred them to petitioner at a price determined by petitioner. On its return for its fiscal year 1986, ADPR elected the cost sharing method as prescribed under sec. 936(h)(5)(C), I.R.C.
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Petitioner, ADC, manufactured combat boots. Its Puerto Rican subsidiary, ADPR, manufactured the uppers for such boots and transferred them to petitioner at a price determined by petitioner. On its return for its fiscal year 1986, ADPR elected the cost sharing method as prescribed under sec. 936(h)(5)(C), I.R.C. That return was due on June 15, 1987, with an extension duly obtained, and was placed in the mail that day with a metered stamp and proper postage for certified mail with return receipt attached. Although other returns mailed the same day by the same individuals in the same box with…
1Opinion of the Court
Altama Delta Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Altama Delta Corp. v. Commissioner
Docket No. 15083-92
United States Tax Court
104 T.C. 424; 1995 U.S. Tax Ct. LEXIS 22; 104 T.C. No. 22;
April 11, 1995, Filed
Decision will be entered under Rule 155.
Petitioner, ADC, manufactured combat boots. Its Puerto Rican subsidiary, ADPR, manufactured the uppers for such boots and transferred them to petitioner at a price determined by petitioner. On its return for its fiscal year 1986, ADPR elected the cost sharing method as prescribed under sec. 936(h)(5)(C), I.R.C. That…
2Cases cited22 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Hagner v. United StatesSupreme Court of the United States · 1932
- Chiu v. CommissionerUnited States Tax Court · 1985
- Estate of Newhouse v. CommissionerUnited States Tax Court · 1990
- Estate of Leonard A. Wood, Deceased, J.M. Loonan, Personal Representative v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1990
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