Bowater, Inc. v. Commissioner
United States Tax Court
Held, P may net interest income against interest expense in determining the amount of the interest deduction to be allocated and apportioned in computing combined taxable income for P and its DISC under sec. 994(a)(2), I.R.C. 1954. Dresser Indus., Inc. v. Commissioner, 911 F.2d 1128 (5th Cir. 1990), revg. on this issue 92 T.C. 1276 (1989), distinguished.
1Opinion of the Court
Bowater Incorporated, f.k.a. Bowater Holdings, Inc., and Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent
Bowater, Inc. v. Commissioner
Docket No. 18436-91
United States Tax Court
101 T.C. 207; 1993 U.S. Tax Ct. LEXIS 56; 101 T.C. No. 14;
September 14, 1993, Filed
An appropriate order will be issued.
Held, P may net interest income against interest expense in determining the amount of the interest deduction to be allocated and apportioned in computing combined taxable income for P and its DISC under sec. 994(a)(2), I.R.C. 1954. Dresser Indus., Inc. v. Commissioner, 911 F.2d…
2Cases cited7 opinions
- Dresser Industries, Inc. And Consolidated Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
- Dresser Industries, Inc. v. CommissionerUnited States Tax Court · 1989
- Ideal Basic Industries, Inc. v. CommissionerUnited States Tax Court · 1984
- St. Jude Medical v. Comm'rUnited States Tax Court · 1991
- Bowater, Inc. v. CommissionerUnited States Tax Court · 1993
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