Legal Opinion
Eli Lilly & Company and Subsidiaries, Cross-Appellees v. Commissioner of Internal Revenue, Cross-Appellant
Court of Appeals for the Seventh Circuit
Decided October 27, 1988No. 86-2911, 86-3116PublishedCited by 45 opinions
1Opinion of the Court
CUDAHY, Circuit Judge.
In 1976, the Commissioner of Internal Revenue (“the Commissioner”) served a notice of deficiency on Eli Lilly and Company (“Lilly”) assessing tax deficiencies against Lilly for the years 1971 through 1973. The bulk of the disputed total amount, roughly $34 million under the Commissioner’s revised calculations, derives from the Commissioner’s reallocation of income to Lilly from Lilly’s subsidiary Eli Lilly and Company, Inc. (“Lilly P.R.”). Lilly P.R. manufactured prescription drugs for Lilly in Puerto Rico taking advantage of tax incentives provided by federal and Puerto…
2Cases cited41 opinions
- Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
- United States v. NixonSupreme Court of the United States · 1974
- Dixon v. United StatesSupreme Court of the United States · 1965
- Hassett v. WelchSupreme Court of the United States · 1938
- Alvin Hunter v. Allis-Chalmers Corporation, Engine Division, and Andre J. Lambert, DefendantsCourt of Appeals for the Seventh Circuit · 1986
36 more not listed; retrieve them via the Exa API.
3Cited by45 opinions
- Joan C. Burnham, Etc. v. The Guardian Life Insurance Company of AmericaCourt of Appeals for the First Circuit · 1989
- Donald A. Peck Judith W. Peck v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1990
- Ronald L. Lerch and Dalene Lerch v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Seventh Circuit · 1989
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1991
- Bausch & Lomb Incorporated and Consolidated Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1991
40 more not listed; retrieve them via the Exa API.