Legal Opinion
DHL Corp. & Subsidiaries v. Commissioner
Court of Appeals for the Ninth Circuit
Decided April 11, 2002No. Nos. 99-71580, 00-70008, 99-71592 and 99-71675PublishedCited by 4 opinions
1Opinion of the Court
OPINION
WILLIAM A. FLETCHER, Circuit Judge.
Petitioner DHL Corporation (“DHL”) appeals the tax court’s affirmance, in part, of the Commissioner of Internal Revenue’s assessment of income tax deficiencies and penalties against petitioner for the tax years 1990-1992, based on the Commissioner’s power to reallocate income between controlled entities .under 26 U.S.C. § 482. Petitioner specifically appeals (1) the § 482 allocation to DHL of additional income arising from DHL’s sale to Document Handling Limited, International (“DHLI”) of the “DHL” trademark, which the tax court valued at $100…
2Cases cited14 opinions
- David G. Collins Pamela Collins Bernie Gates Maureen Gates Anne Hamsley and David Dister v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
- Waterman Steamship Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1970
- Paccar, Inc. And Subsidiaries v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
- Estate of Hilda Ashman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2000
- Estate of J. E. O'connell, James O'COnnell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1981
9 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Weishan v. CommissionerCourt of Appeals for the Ninth Circuit · 2003
- Broderick v. CommissionerCourt of Appeals for the Ninth Circuit · 2003
- Dhl Corporation and Subsidaries v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Dhl Corporation and Subsidiaries, Dhl Corporation and Subsidiaries v. Commissioner of Internal Revenue, Dhl Corporation and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2002
- Parenti v. Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 2003