Vetco, Inc. v. Commissioner
United States Tax Court
VI is a wholly owned Swiss subsidiary of VE, a California corporation. VI is a controlled foreign corporation (CFC) within the meaning of sec. 957(a). VO is a wholly owned U.K. subsidiary of VI. VI, under license from VE, sold pipe connectors for use on offshore oil drilling equipment. Most of the pipe connectors sold by VI were manufactured by I, an unrelated West German company.
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VI is a wholly owned Swiss subsidiary of VE, a California corporation. VI is a controlled foreign corporation (CFC) within the meaning of sec. 957(a). VO is a wholly owned U.K. subsidiary of VI. VI, under license from VE, sold pipe connectors for use on offshore oil drilling equipment. Most of the pipe connectors sold by VI were manufactured by I, an unrelated West German company. The connectors were shipped to VO's plant located in Aberdeen, Scotland, where VO would weld them to pipe and store the pipe assembly until it was shipped to VI's customers, which were unrelated oil companies. VO…
1Opinion of the Court
WRIGHT, Judge:
By notice of deficiency dated October 2, 1986, respondent determined the following deficiencies in and addition to petitioner’s Federal income tax:
_Addition to tax_
TYE Deficiency Sec. 6653(a)1
4/30/74 $289,885 $14,494
4/30/75 8,664,734
Respondent also determined that interest on the deficiency for taxable year ended April 30, 1975, is to be computed under section 6621(c) (formerly section 6621(d)).
After concessions,2 the issues for decision are: (1) Whether the wholly owned United Kingdom subsidiary of a Swiss controlled foreign corporation (CFC) is a branch or similar…
2Cases cited12 opinions
- Achiro v. CommissionerUnited States Tax Court · 1981
- Tauber v. CommissionerUnited States Tax Court · 1955
- McSpadden v. CommissionerUnited States Tax Court · 1968
- Papineau v. CommissionerUnited States Tax Court · 1957
- Estate of Mandels v. CommissionerUnited States Tax Court · 1975
7 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Elec. Arts, Inc. v. Comm'rUnited States Tax Court · 2002
- Caltex Oil Venture v. Comm'rUnited States Tax Court · 2012
- Textron Inc. v. Comm'rUnited States Tax Court · 2001
- Vest v. CommissionerUnited States Tax Court · 1995
- Caltex Oil Venture, Caltex Management Corporation, Tax Matters Partner v. CommissionerUnited States Tax Court · 2012
16 more not listed; retrieve them via the Exa API.