Altama Delta Corp. v. Commissioner
United States Tax Court
Petitioner, ADC, manufactured combat boots. Its Puerto Rican subsidiary, ADPR, manufactured the uppers for such boots and transferred them to petitioner at a price determined by petitioner. On its return for its fiscal year 1986, ADPR elected the cost sharing method as prescribed under sec. 936(h)(5)(C), I.R.C.
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Petitioner, ADC, manufactured combat boots. Its Puerto Rican subsidiary, ADPR, manufactured the uppers for such boots and transferred them to petitioner at a price determined by petitioner. On its return for its fiscal year 1986, ADPR elected the cost sharing method as prescribed under sec. 936(h)(5)(C), I.R.C. That return was due on June 15, 1987, with an extension duly obtained, and was placed in the mail that day with a metered stamp and proper postage for certified mail with return receipt attached. Although other returns mailed the same day by the same individuals in the same box with…
1Opinion of the Court
Scott, Judge:
Respondent determined deficiencies in petitioner’s Federal income taxes for its fiscal years ending the last week of September 1981, 1985, 1986, and 1987 in the amounts as follows:
Fiscal year Deficiency
1981 . $14,688.60
1985 . 691,456.14
1986 ..-.. 332,395.00
1987 . 503,898.00
The issues for decision are: (1) Whether Altama Delta Puerto Rico Corp. (ADPR), a subsidiary of petitioner (ADC), filed a timely Federal income tax return for its fiscal year ending September 27, 1986, claiming an election for the cost sharing method described in section 936(h)(5)(C)(i);1 (2) whether ADPR was…
2Cases cited21 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Hagner v. United StatesSupreme Court of the United States · 1932
- Chiu v. CommissionerUnited States Tax Court · 1985
- Estate of Newhouse v. CommissionerUnited States Tax Court · 1990
- Estate of Leonard A. Wood, Deceased, J.M. Loonan, Personal Representative v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1990
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