American Air Filter Co. v. Commissioner
United States Tax Court
1. P was a U.S. shareholder of wholly owned controlled foreign corporations I, IF, and UK. P intended to receive minimum distributions from each of I and IF for 1974 pursuant to sec. 963, I.R.C. 1954. Because of a clerical oversight, the required election statement was not filed with P's 1974 return; one was provided to the Commissioner during the audit of P's 1974 return.
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1. P was a U.S. shareholder of wholly owned controlled foreign corporations I, IF, and UK. P intended to receive minimum distributions from each of I and IF for 1974 pursuant to sec. 963, I.R.C. 1954. Because of a clerical oversight, the required election statement was not filed with P's 1974 return; one was provided to the Commissioner during the audit of P's 1974 return. Held, P effectively elected to receive minimum distributions from I and IF for 1974 pursuant to sec. 963. 2. P also did not file for 1974 the required statement to elect the 180-day distribution period ( sec. 1.963-3(g)(2),…
1Opinion of the Court
American Air Filter Company, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
American Air Filter Co. v. Commissioner
Docket Nos. 2252-81, 21800-81
United States Tax Court
81 T.C. 709; 1983 U.S. Tax Ct. LEXIS 22; 81 T.C. No. 43;
October 12, 1983, Filed
Decisions will be entered under Rule 155.
1. P was a U.S. shareholder of wholly owned controlled foreign corporations I, IF, and UK. P intended to receive minimum distributions from each of I and IF for 1974 pursuant to sec. 963, I.R.C. 1954. Because of a clerical oversight, the required election statement was not filed with P's 1974…
2Cases cited57 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Angelus Milling Co. v. CommissionerSupreme Court of the United States · 1945
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