Legal Opinion

Teller v. Commissioner

United States Tax Court

Decided July 15, 1992No. Docket No. 20317-88Unpublished

P held stock in two domestic corporations which were engaged in design, manufacture, and sale of electronic products. The products were manufactured or fabricated in the Far East. After experiencing some success, P attempted to sell his products to a domestic chain of nationwide retail electronics outlets. The retailer, as a matter of business policy, would not purchase products manufactured in the Far East from a domestic company.

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P held stock in two domestic corporations which were engaged in design, manufacture, and sale of electronic products. The products were manufactured or fabricated in the Far East. After experiencing some success, P attempted to sell his products to a domestic chain of nationwide retail electronics outlets. The retailer, as a matter of business policy, would not purchase products manufactured in the Far East from a domestic company. The domestic corporations formed foreign subsidiaries with which the national retailer began doing business. The business and assets of the domestic corporations…

1Opinion of the Court

HOWARD S. TELLER AND MEI-LI TELLER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Teller v. Commissioner

Docket No. 20317-88

United States Tax Court

T.C. Memo 1992-402; 1992 Tax Ct. Memo LEXIS 424; 64 T.C.M. (CCH) 166;

July 15, 1992, Filed

Decision will be entered under Rule 155.

P held stock in two domestic corporations which were engaged in design, manufacture, and sale of electronic products. The products were manufactured or fabricated in the Far East. After experiencing some success, P attempted to sell his products to a domestic chain of nationwide retail electronics outlets. The…

2Cases cited23 opinions

  1. Neely v. CommissionerUnited States Tax Court · 1985
  2. Bixby v. CommissionerUnited States Tax Court · 1972
  3. United States v. CartwrightSupreme Court of the United States · 1973
  4. Malat v. RiddellSupreme Court of the United States · 1966
  5. Jasionowski v. CommissionerUnited States Tax Court · 1976

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