Estate of Weiskopf v. Commissioner
United States Tax Court
Petitioners were sole shareholders of A, a domestic corporation. A was organized solely for the purpose of holding stock interests in I, a British overseas trading corporation. R, a British corporation, acquired 50 percent of the voting rights of I upon its incorporation. R was entitled, by articles of association and shareholder agreements, to a 12 1/2-percent cumulative annual dividend and upon liquidation or sale of stock to a return of its investment.
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Petitioners were sole shareholders of A, a domestic corporation. A was organized solely for the purpose of holding stock interests in I, a British overseas trading corporation. R, a British corporation, acquired 50 percent of the voting rights of I upon its incorporation. R was entitled, by articles of association and shareholder agreements, to a 12 1/2-percent cumulative annual dividend and upon liquidation or sale of stock to a return of its investment. I sold products overseas which were manufactured in the United Kingdom by an affiliate of a domestic corporation wholly owned by…
1Opinion of the Court
Wiles, Judge:
Respondent determined deficiencies in petitioners’ income taxes for taxable year ending December 31, 1966, in amounts as follows:
Petitioner Amount of deficiency
Estate of Edwin C. Weiskopf_$481,465.57
Edwin C. and Josephine Whitehead_ 454,329.78
Several issues have been settled by the parties. The remaining issues are: (1) Whether, for purposes of applying section 1248,1 a foreign corporation is a “controlled foreign corporation” as defined in section 957(a); and (2) if determined to be a controlled foreign corporation, whether respondent’s computations under section 1248 are…
2Cases cited8 opinions
- McSpadden v. CommissionerUnited States Tax Court · 1968
- Estate of Jayne v. CommissionerUnited States Tax Court · 1974
- Owens v. CommissionerUnited States Tax Court · 1975
- Gray v. CommissionerUnited States Tax Court · 1971
- Garlock, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1973
3 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Ryan v. CommissionerUnited States Tax Court · 1976
- Framatome Connectors USA, Inc. v. Comm'rUnited States Tax Court · 2002
- Gray v. CommissionerCourt of Appeals for the Ninth Circuit · 1977
- Koehring Company, a Wisconsin Corporation v. United StatesCourt of Appeals for the Seventh Circuit · 1978
- Subscription Television, Inc. v. CommissionerCourt of Appeals for the Fifth Circuit · 1976
11 more not listed; retrieve them via the Exa API.