Fujinon Optical, Inc. v. Commissioner
United States Tax Court
Petitioner, a domestic subsidiary of a foreign parent corporation, is a member of a controlled group as defined in sec. 1563(a), I.R.C. 1954. Petitioner's business is wholly unrelated to that of both other members of the controlled group.
Read the full summary
Petitioner, a domestic subsidiary of a foreign parent corporation, is a member of a controlled group as defined in sec. 1563(a), I.R.C. 1954. Petitioner's business is wholly unrelated to that of both other members of the controlled group. Of petitioner's 15 employees in 1976, 8 were covered by its profit-sharing plan and the remaining 7 were excluded under the minimum age and service conditions of sec. 410(a)(1). When all employees of all three members of the controlled group are treated as employed by a single employer pursuant to sec. 414(b), the numerical test of sec. 410(b)(1)(A) could…
1Opinion of the Court
Fujinon Optical, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Fujinon Optical, Inc. v. Commissioner
Docket No. 12035-79R
United States Tax Court
76 T.C. 499; 1981 U.S. Tax Ct. LEXIS 151; 2 Employee Benefits Cas. (BNA) 1145;
March 31, 1981, Filed
Decision will be entered for the respondent.
Petitioner, a domestic subsidiary of a foreign parent corporation, is a member of a controlled group as defined in sec. 1563(a), I.R.C. 1954. Petitioner's business is wholly unrelated to that of both other members of the controlled group. Of petitioner's 15 employees in 1976, 8 were covered by…
2Cases cited14 opinions
- Commissioner of Internal Revenue v. Pepsi-Cola Niagara Bottling CorporationCourt of Appeals for the Second Circuit · 1968
- Ed & Jim Fleitz, Inc. v. CommissionerUnited States Tax Court · 1968
- Loevsky v. CommissionerUnited States Tax Court · 1971
- Pepsi-Cola Niagara Bottling Corp. v. CommissionerUnited States Tax Court · 1967
- Tamko Asphalt Products, Inc. v. CommissionerUnited States Tax Court · 1979
9 more not listed; retrieve them via the Exa API.