Hewlett-Packard Co. v. Commissioner
United States Tax Court
1. Held, petitioner substantially complied with the directions of sec. 1.964-1(c)(3), Income Tax Regs., prescribing the procedure for the election of depreciation accounting methods, and the earnings and profits of three of its controlled foreign subsidiaries for the taxable years ended Oct. 31 of 1967 through 1970, properly reflected adjustments for accelerated depreciation. 2. Held, further, petitioner did not satisfy the "minimum overall tax burden" test prescribed by…
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1. Held, petitioner substantially complied with the directions of sec. 1.964-1(c)(3), Income Tax Regs., prescribing the procedure for the election of depreciation accounting methods, and the earnings and profits of three of its controlled foreign subsidiaries for the taxable years ended Oct. 31 of 1967 through 1970, properly reflected adjustments for accelerated depreciation. 2. Held, further, petitioner did not satisfy the "minimum overall tax burden" test prescribed by sec. 1.963-4(a), Income Tax Regs., and is not entitled to exclude for its taxable year ended Oct. 31, 1968, the subpart F…
1Opinion of the Court
Hewlett-Packard Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Hewlett-Packard Co. v. Commissioner
Docket No. 3151-75
United States Tax Court
67 T.C. 736; 1977 U.S. Tax Ct. LEXIS 159;
January 31, 1977, Filed
1. Held, petitioner substantially complied with the directions of sec. 1.964-1(c)(3), Income Tax Regs., prescribing the procedure for the election of depreciation accounting methods, and the earnings and profits of three of its controlled foreign subsidiaries for the taxable years ended Oct. 31 of 1967 through 1970, properly reflected adjustments for accelerated…
2Cases cited10 opinions
- Bogardus v. CommissionerSupreme Court of the United States · 1937
- Reaver v. CommissionerUnited States Tax Court · 1964
- Sperapani v. CommissionerUnited States Tax Court · 1964
- Cary v. CommissionerUnited States Tax Court · 1963
- Columbia Iron & Metal Co. v. CommissionerUnited States Tax Court · 1973
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