Chevron Corp. v. Commissioner
United States Tax Court
This case concerns the allocation and apportionment of certain State taxes between domestic and foreign source gross income. Secs. 861(b) and 862(b), I.R.C. Resolution of that issue will determine the extent to which Ps may take a credit for foreign taxes under sec. 901, I.R.C. Ps have brought into question the validity of sec. 1.861-8(e)(6)(i), Income Tax Regs.
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This case concerns the allocation and apportionment of certain State taxes between domestic and foreign source gross income. Secs. 861(b) and 862(b), I.R.C. Resolution of that issue will determine the extent to which Ps may take a credit for foreign taxes under sec. 901, I.R.C. Ps have brought into question the validity of sec. 1.861-8(e)(6)(i), Income Tax Regs. The principal State tax with which we deal is the California bank and corporation franchise tax (a so-called unitary tax, imposing "worldwide combined reporting"). 1. Held, Ps' alternative methods of allocating and apportioning State…
1Opinion of the Court
Chevron Corporation and Affiliated Companies, Petitioners v. Commissioner of Internal Revenue, Respondent
Chevron Corp. v. Commissioner
Docket No. 24954-90
United States Tax Court
104 T.C. 719; 1995 U.S. Tax Ct. LEXIS 35; 104 T.C. No. 35;
June 27, 1995, Filed
An appropriate order will be issued.
This case concerns the allocation and apportionment of certain State taxes between domestic and foreign source gross income. Secs. 861(b) and 862(b), I.R.C. Resolution of that issue will determine the extent to which Ps may take a credit for foreign taxes under sec. 901, I.R.C. Ps have brought into question…
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- United States v. CorrellSupreme Court of the United States · 1967
- Container Corp. of America v. Franchise Tax BoardSupreme Court of the United States · 1983
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- United States v. Vogel Fertilizer Co.Supreme Court of the United States · 1982
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