Microsoft Corp. v. Commissioner
United States Tax Court
During 1990 and 1991, petitioner engaged its wholly owned subsidiary, a foreign sales corporation, to act as its agent for the international sales of standardized mass-marketed computer software products and computer software masters. The standardized software products were copyrighted articles sold without a right to reproduce abroad.
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During 1990 and 1991, petitioner engaged its wholly owned subsidiary, a foreign sales corporation, to act as its agent for the international sales of standardized mass-marketed computer software products and computer software masters. The standardized software products were copyrighted articles sold without a right to reproduce abroad. The software masters were licensed to related foreign subsidiaries and unrelated foreign equipment manufacturers with a right to reproduce abroad. In the notices of deficiency, respondent allowed the deductions for the foreign sales corporation commissions…
1Opinion of the Court
MICROSOFT CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Microsoft Corp. v. Commissioner
No. 16878-96
United States Tax Court
115 T.C. 228; 2000 U.S. Tax Ct. LEXIS 63; 115 T.C. No. 17;
September 15, 2000, Filed
Decision will be entered under Rule 155.
During 1990 and 1991, petitioner engaged its wholly owned
subsidiary, a foreign sales corporation, to act as its agent for
the international sales of standardized mass-marketed computer
software products and computer software masters. The
standardized software products were copyrighted articles sold
without a right to reproduce…
2Cases cited23 opinions
- Central Bank of Denver, N. A. v. First Interstate Bank of Denver, N. A.Supreme Court of the United States · 1994
- United States v. CorrellSupreme Court of the United States · 1967
- United States v. Riverside Bayview Homes, Inc.Supreme Court of the United States · 1985
- United States v. CartwrightSupreme Court of the United States · 1973
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
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