Trinity Indus. v. Comm'r
United States Tax Court
Company T, a member of P's affiliated group, contracted to build barges for two established customers; pursuant to an interim financing arrangement, part of the purchase price was deferred until 18 months after the delivery of each barge.
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Company T, a member of P's affiliated group, contracted to build barges for two established customers; pursuant to an interim financing arrangement, part of the purchase price was deferred until 18 months after the delivery of each barge. The two customers later claimed damages from alleged defects in barges that they had previously purchased from T under earlier contracts; they withheld deferred payments due under the later contract, asserting common law rights to offset the deferred payments against their claimed damages under the earlier contracts. In reporting the affiliated group's 2002…
1Opinion of the Court
TRINITY INDUSTRIES, INC. AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Trinity Indus. v. Comm'r
No. 12395-06
United States Tax Court
132 T.C. 6; 2009 U.S. Tax Ct. LEXIS 2; 132 T.C. No. 2;
January 28, 2009., Filed
Company T, a member of P's affiliated group, contracted to build barges for two established customers; pursuant to an interim financing arrangement, part of the purchase price was deferred until 18 months after the delivery of each barge. The two customers later claimed damages from alleged defects in barges that they had previously purchased from T under…
2Cases cited22 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Commissioner v. HansenSupreme Court of the United States · 1959
- Cal-Maine Foods, Inc. v. CommissionerUnited States Tax Court · 1989
- Marshall M. Chernin Ida Raye Chernin, Cross-Appellants/appellees v. United States of America, Appellant/cross-AppelleeCourt of Appeals for the Eighth Circuit · 1998
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