Dover Corp. v. Comm'r
United States Tax Court
D and H, United Kingdom corporations, were controlled foreign corporations with respect to P. H was a wholly owned subsidiary of D. In 1997, D sold the stock of H to an unrelated third party. In 1999, P requested that H be granted an extension of time to retroactively elect to be treated as a "disregarded entity" pursuant to sec. 301.7701-3, Proced. & Admin. Regs., effective "immediately prior to" D's sale of the H stock.
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D and H, United Kingdom corporations, were controlled foreign corporations with respect to P. H was a wholly owned subsidiary of D. In 1997, D sold the stock of H to an unrelated third party. In 1999, P requested that H be granted an extension of time to retroactively elect to be treated as a "disregarded entity" pursuant to sec. 301.7701-3, Proced. & Admin. Regs., effective "immediately prior to" D's sale of the H stock. R granted the requested extension of time on Mar. 31, 2000. H's retroactive disregarded entity election was filed on or about Oct. 10, 1999. Pursuant to that election, there…
1Opinion of the Court
DOVER CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Dover Corp. v. Comm'r
No. 12821-00
United States Tax Court
122 T.C. 324; 2004 U.S. Tax Ct. LEXIS 19; 122 T.C. No. 19;
May 5, 2004, Filed
Decision was entered for Petitioner.
D and H, United Kingdom corporations, were controlled
foreign corporations with respect to P. H was a wholly owned
subsidiary of D. In 1997, D sold the stock of H to an unrelated
third party. In 1999, P requested that H be granted an extension
of time to retroactively elect to be treated as a
"disregarded entity" pursuant to sec. 301.7701-3,
2Cases cited27 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Rowan Cos. v. United StatesSupreme Court of the United States · 1981
- Rothensies v. Electric Storage Battery Co.Supreme Court of the United States · 1946
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- United States v. MichelSupreme Court of the United States · 1931
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