CWT Farms, Inc. v. Commissioner
United States Tax Court
In CWT Farms, Inc. v. Commissioner, 79 T.C. 86 (1982), we held that I did not qualify as a DISC because its loans to F were not "producer's loans" within the meaning of sec. 993(d), I.R.C. 1954, and were not, therefore, qualified export assets within the meaning of sec. 993(b). I has indicated that it wishes to make a deficiency distribution in accordance with sec. 992(c), I.R.C. 1954, and asks us to decide whether its commissions receivable constitute qualified export…
Read the full summary
In CWT Farms, Inc. v. Commissioner, 79 T.C. 86 (1982), we held that I did not qualify as a DISC because its loans to F were not "producer's loans" within the meaning of sec. 993(d), I.R.C. 1954, and were not, therefore, qualified export assets within the meaning of sec. 993(b). I has indicated that it wishes to make a deficiency distribution in accordance with sec. 992(c), I.R.C. 1954, and asks us to decide whether its commissions receivable constitute qualified export assets. Secs. 1.993-2(d)(2) and 1.994-1(e)(3), Income Tax Regs., provide that commissions receivable owed by a related person…
1Opinion of the Court
SUPPLEMENTAL OPINION
Simpson, Judge:
On July 19, 1982, this Court filed its findings of fact and opinion in this case (79 T.C. 86), in which we held that petitioner CWT International, Inc. (International), did not qualify as a domestic international sales corporation (DISC) for its taxable years ending in 1975, 1976, and 1977. Our holding was based on the conclusion that certain loans from International to petitioner CWT Farms, Inc. (Farms), were not "producer’s loans” under section 993(d) of the Internal Revenue Code of 1954,1 and that, therefore, such loans were not qualified export assets…
2Cases cited39 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- United States v. CorrellSupreme Court of the United States · 1967
- Bingler v. JohnsonSupreme Court of the United States · 1969
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
34 more not listed; retrieve them via the Exa API.
3Cited by72 opinions
- Huntsberry v. CommissionerUnited States Tax Court · 1984
- Cwt Farms, Inc. And Cwt International, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
- Westbrook v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
- Lecroy Research Systems Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1984
- ESTATE OF QUICK v. COMMISSIONERUnited States Tax Court · 1998
67 more not listed; retrieve them via the Exa API.