Brown Group v. Commissioner
United States Tax Court
P1 is a member of an affiliated group of corporations that filed a consolidated Federal corporate income tax return for the year in issue. P is the parent of the affiliated group. R determined that P1's distributive share of a foreign partnership's (FP's) income is foreign base company sales income that is includable in the consolidated gross income of P as subpart F income.
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P1 is a member of an affiliated group of corporations that filed a consolidated Federal corporate income tax return for the year in issue. P is the parent of the affiliated group. R determined that P1's distributive share of a foreign partnership's (FP's) income is foreign base company sales income that is includable in the consolidated gross income of P as subpart F income. Relying on the holding in Rev. Rul. 89-72, 1989-1 C.B. 257, R contends that the income P1 received from FP should be considered as if earned by P1 directly from the source from which received by FP. P contends that P1's…
1Opinion of the Court
BROWN GROUP, INC. AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Brown Group v. Commissioner
Docket No. 104-92
United States Tax Court
102 T.C. 616; 1994 U.S. Tax Ct. LEXIS 26; 102 T.C. No. 24;
April 12, 1994, Filed
P1 is a member of an affiliated group of corporations that filed a consolidated Federal corporate income tax return for the year in issue. P is the parent of the affiliated group. R determined that P1's distributive share of a foreign partnership's (FP's) income is foreign base company sales income that is includable in the consolidated gross income of P as…
2Cases cited35 opinions
- Bull v. United StatesSupreme Court of the United States · 1935
- Weiss v. WeinerSupreme Court of the United States · 1929
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
- Brannen v. CommissionerUnited States Tax Court · 1982
- United States v. BasyeSupreme Court of the United States · 1973
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