Addison International, Inc. v. Commissioner
United States Tax Court
P, a DISC, was organized and operated in reliance upon the handbook, a guidebook for DISC's issued by the Department of the Treasury. P held no property, had neither employees nor place of business, and conducted no activity beyond those steps necessary to ensure qualification as a DISC.
Read the full summary
P, a DISC, was organized and operated in reliance upon the handbook, a guidebook for DISC's issued by the Department of the Treasury. P held no property, had neither employees nor place of business, and conducted no activity beyond those steps necessary to ensure qualification as a DISC. R sent a statutory notice of deficiency to P in which R determined that P failed to qualify as a DISC for taxable years 1976 and 1977 on the ground that a commission payment was not made within the 60-day period allowed by regulation. Held: Because P was entitled to rely on the handbook, the regulation cannot…
1Opinion of the Court
Addison International, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Addison International, Inc. v. Commissioner
Docket No. 6058-82
United States Tax Court
90 T.C. 1207; 1988 U.S. Tax Ct. LEXIS 76; 90 T.C. No. 78;
June 21, 1988. June 21, 1988, Filed
Decision will be entered for the respondent with respect to taxable year 1977.
Decision will be entered for the petitioner with respect to taxable year 1976.
P, a DISC, was organized and operated in reliance upon the handbook, a guidebook for DISC's issued by the Department of the Treasury. P held no property, had neither employees nor…
Also in this document: Dissent · Gerber; Dissent · Ruwe.
2Cases cited28 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Lucas v. EarlSupreme Court of the United States · 1930
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- Stubbs, Overbeck & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971
23 more not listed; retrieve them via the Exa API.