Bowater, Inc. v. Commissioner
United States Tax Court
Held, P may net interest income against interest expense in determining the amount of the interest deduction to be allocated and apportioned in computing combined taxable income for P and its DISC under sec. 994(a)(2), I.R.C. 1954. Dresser Indus., Inc. v. Commissioner, 911 F.2d 1128 (5th Cir. 1990), revg. on this issue 92 T.C. 1276 (1989), distinguished.
1Opinion of the Court
Colvin, Judge:
Respondent determined deficiencies in petitioner’s Federal income tax of $3,231,988 for 1976, $5,214,010 for 1979, and $27,096,396 for 1980.
The issue for decision is whether petitioner may net interest income against interest expense in determining the amount of the interest deduction to be allocated and apportioned in computing the combined taxable income (CTl) of petitioner and its domestic international sales corporations (disc’s). We hold that petitioner may.
As explained below, we distinguish Dresser Indus., Inc. v. Commissioner, 911 F.2d 1128 (5th Cir. 1990), revg. on this…
2Cases cited6 opinions
- Dresser Industries, Inc. And Consolidated Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
- Dresser Industries, Inc. v. CommissionerUnited States Tax Court · 1989
- Ideal Basic Industries, Inc. v. CommissionerUnited States Tax Court · 1984
- St. Jude Medical v. Comm'rUnited States Tax Court · 1991
- General Portland Cement Co., Cross-Appellant v. United States of America, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1980
1 more not listed; retrieve them via the Exa API.
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- Texasgulf, Inc. v. CommissionerUnited States Tax Court · 1996
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