Brittingham v. Commissioner
United States Tax Court
Two brothers, Robert and Juan (together with their immediate families), each owned a 37-percent interest in D, a Texas corporation. D purchased tile from C, a Mexican corporation, for resale in the United States. Juan and his family owned and controlled C. The price D paid for such tile was substantially higher than the customs value as determined by the U.S. Bureau of Customs.
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Two brothers, Robert and Juan (together with their immediate families), each owned a 37-percent interest in D, a Texas corporation. D purchased tile from C, a Mexican corporation, for resale in the United States. Juan and his family owned and controlled C. The price D paid for such tile was substantially higher than the customs value as determined by the U.S. Bureau of Customs. Held: (1) D and C were not owned or controlled by the same interests within the meaning of sec. 482, I.R.C. 1954; (2) D paid an arm's-length price for the tile purchased from C; (3) no part of the payments by D for…
1Opinion of the Court
Robert M. Brittingham, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Brittingham v. Commissioner
Docket Nos. 6626-71, 6627-71, 6631-71, 7774-71, 7810-71
United States Tax Court
66 T.C. 373; 1976 U.S. Tax Ct. LEXIS 98;
June 3, 1976, Filed
Decisions will be entered under Rule 155.
Two brothers, Robert and Juan (together with their immediate families), each owned a 37-percent interest in D, a Texas corporation. D purchased tile from C, a Mexican corporation, for resale in the United States. Juan and his family owned and controlled C. The price D paid for such tile was…
2Cases cited71 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- Mitchell v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1941
- Palmer v. CommissionerSupreme Court of the United States · 1937
- Electric & Neon, Inc. v. CommissionerUnited States Tax Court · 1971
- Charles Oran Mensik and Mary Mensik v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1964
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