Legal Opinion
McCoy Enterprises, Inc., & Subsidiaries v. Commissioner of Internal Revenue
Court of Appeals for the Tenth Circuit
Decided June 20, 1995No. 93-9014PublishedCited by 24 opinions
1Opinion of the Court
EBEL, Circuit Judge.
This case involves the special tax treatment of domestic international sales corporations (“DISCs”). Petitioners-Appellants McCoy Enterprises and Subsidiaries (collectively, “McCoy”) created a wholly-owned sub sidiary to account for its foreign sales and to take advantage of the tax benefits given to DISCs. The net income of the subsidiary was distributed to its parent as a “loan” each year and carried on the subsidiary’s books as an account receivable. McCoy maintains that these amounts were not really loans, but were actually distributions to the parent shareholder…
2Cases cited17 opinions
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Pierce v. CommissionerUnited States Tax Court · 1974
- Unvert v. CommissionerUnited States Tax Court · 1979
- Allen P. Unvert and Catherine R. Unvert v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1981
- Cramer v. CommissionerUnited States Tax Court · 1993
12 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Magana v. Comm'rUnited States Tax Court · 2002
- Robinette v. Comm'rUnited States Tax Court · 2004
- Martin Ice Cream Co. v. Comm'rUnited States Tax Court · 1998
- Donald Merino Rosemarie Merino v. Commissioner of Internal Revenue, DefendentsCourt of Appeals for the Third Circuit · 1999
- Schelble v. CommissionerCourt of Appeals for the Tenth Circuit · 1997
19 more not listed; retrieve them via the Exa API.