Seagate Technology v. Commissioner
United States Tax Court
P, a corporation whose stock is publicly traded, is a leading manufacturer of hard disk drives for personal computers. During its fiscal year ended 1983, P organized S as a wholly owned subsidiary to manufacture component parts in Singapore for use by P in the manufacture of hard disk drives in the United States. During its fiscal year ended 1984, P expanded S's operations to include the manufacture of completed disk drives in Singapore.
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P, a corporation whose stock is publicly traded, is a leading manufacturer of hard disk drives for personal computers. During its fiscal year ended 1983, P organized S as a wholly owned subsidiary to manufacture component parts in Singapore for use by P in the manufacture of hard disk drives in the United States. During its fiscal year ended 1984, P expanded S's operations to include the manufacture of completed disk drives in Singapore. P contributed to S's capital certain intangibles for use in the manufacture of the completed disk drives. P purchases component parts from S for use in disk…
1Opinion of the Court
Seagate Technology, Inc. and Consolidated Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent
Seagate Technology v. Commissioner
Docket No. 11660-90
United States Tax Court
102 T.C. 149; 1994 U.S. Tax Ct. LEXIS 10; 102 T.C. No. 9;
February 8, 1994, Filed
Decision will be entered under Rule 155.
P, a corporation whose stock is publicly traded, is a leading manufacturer of hard disk drives for personal computers. During its fiscal year ended 1983, P organized S as a wholly owned subsidiary to manufacture component parts in Singapore for use by P in the manufacture of hard disk…
2Cases cited23 opinions
- Daubert v. Merrell Dow Pharmaceuticals, Inc.Supreme Court of the United States · 1993
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
- Parker v. CommissionerUnited States Tax Court · 1986
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