Legal Opinion
E. I. du Pont de Nemours & Co. v. United States
United States Court of Claims
Decided October 17, 1979No. Nos. 256-66, 371-66PublishedCited by 22 opinions
1Opinion of the CourtDavis, Judge
Taxpayer Du Pont de Nemours, the American chemical concern, created early in 1959 a wholly-owned Swiss marketing and sales subsidiary for foreign sales — Du Pont International S.A. (known to the record and the parties as DISA). Most of the Du Pont chemical products marketed abroad were first sold by taxpayer to DISA, which then arranged for resale to the ultimate consumer through independent distributors. The profits on these Du Pont sales were divided for income tax purposes between plaintiff and DISA via the mechanism of the prices plaintiff charged DISA. For 1959 and 1960 the Commissioner…
2Cases cited10 opinions
- Young & Rubicam, Inc. v. The United StatesUnited States Court of Claims · 1969
- PPG Indus., Inc. v. CommissionerUnited States Tax Court · 1970
- Eli Lilly & Co. v. United StatesUnited States Court of Claims · 1967
- American Terrazzo Strip Co. v. CommissionerUnited States Tax Court · 1971
- Major Coat Co. v. United StatesUnited States Court of Claims · 1976
5 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Foster v. Comm'rUnited States Tax Court · 1983
- Montgomery Coca-Cola Bottling Co. v. United StatesUnited States Court of Claims · 1980
- Eli Lilly & Company and Subsidiaries, Cross-Appellees v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Seventh Circuit · 1988
- Bausch & Lomb, Inc. v. CommissionerUnited States Tax Court · 1989
- United States v. Toyota Motor Corp.District Court, C.D. California · 1983
17 more not listed; retrieve them via the Exa API.