Avon Products, Inc. And U.S. Subsidiaries v. United States
Court of Appeals for the Federal Circuit
1Opinion of the Court
BRYSON, Circuit Judge..
This appeal stems from a dispute over the appropriate tax treatment of employee profit-sharing payments made by the Mexican subsidiary of a United States taxpayer, Avon Products, Inc. The Court of Federal Claims granted summary judgment for the government on the ground that the subsidiary had improperly deducted certain payments in the year in which the payments were made rather than in the year in which the employees’ services were rendered. Avon Prods., Inc. v. United States, No. 94-485 T, 1995 WL 579706. We conclude that the government is not entitled to summary…
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