Legal Opinion
Medchem (P.R.), Inc. v. Commissioner
Court of Appeals for the First Circuit
Decided July 10, 2002No. 01-2251PublishedCited by 15 opinions
1Opinion of the Court
LYNCH, Circuit Judge.
This tax case requires interpretation of the Internal Revenue Code’s Puerto Rico and Possession Tax Credit provision, 26 U.S.C. § 936 (2000), which permits a domestic corporation to elect a possession tax credit if it meets certain conditions, id. § 936(a). The condition on which this case turns is that 75% or more of the gross income of the corporation for the three preceding years must be “derived from the active conduct of a trade or business within a possession of the United States.” Id. § 936(a)(2)(B). 1
The taxpayer, MedChem (P.R.), Inc. (“M-PR”), contends that it…
2Cases cited24 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Commissioner v. GroetzingerSupreme Court of the United States · 1987
- United States v. StewartSupreme Court of the United States · 1940
- White v. United StatesSupreme Court of the United States · 1938
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3Cited by15 opinions
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- Textron Inc. v. Commissioner of IRSCourt of Appeals for the First Circuit · 2003
- Clearmeadow Investments, LLC v. United StatesUnited States Court of Federal Claims · 2009
- Interex, Inc. v. Commissioner ofCourt of Appeals for the First Circuit · 2003
- Capital Video Corp. v. CommissionerCourt of Appeals for the First Circuit · 2002
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