Bausch & Lomb, Inc. v. Commissioner
United States Tax Court
Petitioner and its subsidiaries engaged in the manufacture, marketing, and sale of soft contact lenses and related products in the United States and abroad. B&L Ireland was organized on Feb. 1, 1980, under the laws of the Republic of Ireland as a third tier, wholly owned subsidiary of petitioner. B&L Ireland was organized for valid business reasons and to take advantage of certain tax and other incentives offered by the Republic of Ireland.
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Petitioner and its subsidiaries engaged in the manufacture, marketing, and sale of soft contact lenses and related products in the United States and abroad. B&L Ireland was organized on Feb. 1, 1980, under the laws of the Republic of Ireland as a third tier, wholly owned subsidiary of petitioner. B&L Ireland was organized for valid business reasons and to take advantage of certain tax and other incentives offered by the Republic of Ireland. Pursuant to an agreement dated Jan. 1, 1981, petitioner granted to B&L Ireland a nonexclusive license to use its patented and unpatented manufacturing…
1Opinion of the Court
KÓRNER, Judge:
Respondent determined deficiencies in petitioners’ consolidated corporate Federal income tax in the amounts and for the years as follows:
TYE Deficiency
Dec. 30, 1979. $5,797,857
Dec. 28, 1980. 514,141
Dec. 27, 1981. 2,714,394
The determination of petitioners’ 1979, 1980, and 1981 United States consolidated taxable income requires a determination as to petitioners’ United States consolidated taxable income for the year 1982 due to net operating loss and foreign tax credit carrybacks.
Among other adjustments made by respondent in his statutory notice, respondent determined that income…
2Cases cited24 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Chiu v. CommissionerUnited States Tax Court · 1985
- Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
19 more not listed; retrieve them via the Exa API.
3Cited by41 opinions
- Ewing v. Comm'rUnited States Tax Court · 2004
- Robinette v. Comm'rUnited States Tax Court · 2004
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1991
- Bausch & Lomb Incorporated and Consolidated Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1991
- Porter v. Comm'rUnited States Tax Court · 2008
36 more not listed; retrieve them via the Exa API.