Estate of Whitlock v. Commissioner
United States Tax Court
For 1963 Oil Services was a controlled foreign corporation and for 1964, 1965, and 1967, it was both a controlled foreign corporation and a foreign personal holding company. For each of those years Oil Services had an increase in its earnings invested in U.S. property as defined in sec. 956. Petitioners were Oil Services' only shareholders and were its only U.S. shareholders. For 1964, 1965, and 1967, they were subject to tax under sec. 551(b) on Oil Services' income.
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For 1963 Oil Services was a controlled foreign corporation and for 1964, 1965, and 1967, it was both a controlled foreign corporation and a foreign personal holding company. For each of those years Oil Services had an increase in its earnings invested in U.S. property as defined in sec. 956. Petitioners were Oil Services' only shareholders and were its only U.S. shareholders. For 1964, 1965, and 1967, they were subject to tax under sec. 551(b) on Oil Services' income. Held: For 1964, 1965, and 1967, petitioners were not required to include in their gross income any part of Oil Services'…
1Opinion of the Court
OPINION
FORRESTER, Judge:
Respondent determined deficiencies in petitioners’ income tax of $25,106.64, $1,552.76, $17,328.88, and $141,-985.23 for the taxable years 1963, 1964, 1965, and 1967, respectively. The main issue we must decide is whether petitioners, who, for the taxable years 1964, 1965, and 1967, were U.S. shareholders subject to tax under section 551(b) 1 on income of a controlled foreign corporation, were required to include in gross income for such taxable years any amounts under section 951(a) with respect to such corporation. In addition, we must pass upon the constitutionality…
2Cases cited37 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Higgins v. SmithSupreme Court of the United States · 1940
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3Cited by23 opinions
- Dougherty v. CommissionerUnited States Tax Court · 1973
- Dow Chemical Co. v. Commissioner of RevenueMassachusetts Supreme Judicial Court · 1979
- Estate of Leonard E. Whitlock, Deceased, Cross-Appellants v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Tenth Circuit · 1974
- Vetco, Inc. v. CommissionerUnited States Tax Court · 1990
- Riverfront Groves, Inc. v. CommissionerUnited States Tax Court · 1973
18 more not listed; retrieve them via the Exa API.