Legal Opinion

Computervision Corp. v. Commissioner

United States Tax Court

Decided April 16, 1991No. Docket No. 17527-88Published

P, a manufacturer of computer products, utilized a domestic international sales corporation (DISC) as a commission agent for export sales of its products. Held, combined taxable income (CTI) of P and its DISC computed under full cost accounting must be reduced by the full amount of discount incurred on the transfer of export accounts receivable from P to its DISC.

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P, a manufacturer of computer products, utilized a domestic international sales corporation (DISC) as a commission agent for export sales of its products. Held, combined taxable income (CTI) of P and its DISC computed under full cost accounting must be reduced by the full amount of discount incurred on the transfer of export accounts receivable from P to its DISC. Dresser Industries v. Commissioner, 92 T.C. 1276 (1989), affd. in part, revd. on an unrelated issue 911 F.2d 1128 (5th Cir. 1990), followed. Held, further, discount is incorporated into the computation of CTI of P and its DISC under…

1Opinion of the Court

Computervision Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent

Computervision Corp. v. Commissioner

Docket No. 17527-88

United States Tax Court

96 T.C. 652; 1991 U.S. Tax Ct. LEXIS 31; 96 T.C. No. 25;

April 16, 1991, Filed

Decision will be entered under Rule 155.

P, a manufacturer of computer products, utilized a domestic international sales corporation (DISC) as a commission agent for export sales of its products. Held, combined taxable income (CTI) of P and its DISC computed under full cost accounting must be reduced by the full amount of discount incurred on the transfer…

2Cases cited14 opinions

  1. Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
  2. Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
  3. Columbian Rope Co. v. CommissionerUnited States Tax Court · 1964
  4. Dresser Industries, Inc. And Consolidated Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
  5. Thomas International Limited v. The United StatesCourt of Appeals for the Federal Circuit · 1985

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