Legal Opinion
IDC Research, Inc. v. Commissioner of Revenue
Massachusetts Appeals Court
Decided November 30, 2010No. 09-P-1533PublishedCited by 4 opinions
1Opinion of the CourtBrown, J.
IDC Research, Inc., appeals from a decision of the Appellate Tax Board (board), upholding the refusal of the Commissioner of Revenue (commissioner) to abate a portion of the corporate excise taxes assessed to its parent corporation, International Data Group (IDG), for the tax years 1992, 1993, and 1994. IDG disputes that it owes taxes on royalty income received by IDG Holdings, Inc. (IDG Holdings), an IDG subsidiary incorporated in Delaware.
For the facts, we refer to the board’s April 17, 2009, findings of fact and report. The board concluded that the commissioner properly reallocated royalty…
2Cases cited17 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Higgins v. SmithSupreme Court of the United States · 1940
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Commissioner v. BanksSupreme Court of the United States · 2005
- Northern Indiana Public Service Company v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Seventh Circuit · 1997
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3Cited by4 opinions
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