Legal Opinion
McA Inc. And Universal City Studios, Inc. v. United States
Court of Appeals for the Ninth Circuit
Decided August 27, 1982No. 80-5510PublishedCited by 21 opinions
1Opinion of the Court
NORRIS, Circuit Judge:
This appeal presents the question whether unincorporated foreign organizations, jointly owned by a controlled foreign corporation and an employee trust, should be characterized as corporations or partnerships for domestic tax purposes. The Commissioner of Internal Revenue determined that the organizations were corporations, and assessed a deficiency of $868,170 against MCA, an indirect owner of the organizations. MCA paid the deficiency and filed this action for a refund, contending that the organizations are partnerships within the meaning of Treas.Reg. § 301.-7701-2,…
2Cases cited10 opinions
- United States v. Olympic Radio & Television, Inc.Supreme Court of the United States · 1955
- Henry C. Beck Builders, Inc. v. CommissionerUnited States Tax Court · 1964
- Commercial Insurance Co. of Newark v. Pacific-Peru Construction Corp.Court of Appeals for the Ninth Circuit · 1977
- Howard A. Kurzner and C. A. Kurzner v. United StatesCourt of Appeals for the Fifth Circuit · 1969
- Coberly v. Superior CourtCalifornia Court of Appeal · 1965
5 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Rocio Henriquez-Rivas v. Eric Holder, Jr.Court of Appeals for the Ninth Circuit · 2013
- Penny v. WilsonCalifornia Court of Appeal · 2004
- Brown Group v. CommissionerUnited States Tax Court · 1995
- Brown Group, Inc. And Its Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1996
- Leila G. Newhall Unitrust, Wells Fargo Bank, Trustee v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1997
16 more not listed; retrieve them via the Exa API.