Gulf Oil Corp. v. Commissioner
United States Tax Court
Afran, a wholly owned foreign subsidiary of P, in the normal course of business, chartered several tanker vessels to Gulftankers, another wholly owned foreign subsidiary of P. Charter hire rates between Afran and Gulftankers were established at the beginning of each year based upon estimates of the rate that would be charged in an arm's-length transaction. In 1975, P decided to consolidate its foreign marine operations.
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Afran, a wholly owned foreign subsidiary of P, in the normal course of business, chartered several tanker vessels to Gulftankers, another wholly owned foreign subsidiary of P. Charter hire rates between Afran and Gulftankers were established at the beginning of each year based upon estimates of the rate that would be charged in an arm's-length transaction. In 1975, P decided to consolidate its foreign marine operations. As a result, P caused Gulftankers to transfer all of its operating assets to Afran in exchange for a payment obligation from Afran before liquidating into P effective Dec. 29,…
1Opinion of the Court
GOFFE, Judge:
The Commissioner determined deficiencies in petitioner’s Federal income tax for the taxable year 1974 in the amount of $80,813,428 and for the taxable year 1975 in the amount of $166,316,320. Petitioner and respondent, by motion granted on November 10, 1983, agreed that certain issues would be severed and tried at a special trial session, which was held at Dallas, Texas.
One of the group of issues tried was designated by the parties as “Constructive Dividends and Payables.” This group requires the resolution of three issues: (1) Did the retroactive adjustment of marine charter…
2Cases cited15 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Irving Sachs v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1960
- Rushing v. CommissionerUnited States Tax Court · 1969
- W. B. Rushing v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
- Sachs v. CommissionerUnited States Tax Court · 1959
10 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
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- Jerry Lipps, Inc. v. CommissionerUnited States Tax Court · 1990
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