Coca-Cola Co. v. Commissioner
United States Tax Court
P filed a motion for partial summary judgment relating to the computation of combined taxable income under sec. 936(h)(5)(C)(ii), I.R.C., with respect to syrup and soft-drink concentrate produced by P's sec. 936, I.R.C., subsidiary, Caribbean Refrescos, Inc. 1. Held:Sec. 1.936-6(b)(1), Q&A-12, Income Tax Regs., governs the computation of combined taxable income with respect to sales of component concentrate to unrelated third parties. 2. Held, further,sec. 1.936-6(b)(1),…
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P filed a motion for partial summary judgment relating to the computation of combined taxable income under sec. 936(h)(5)(C)(ii), I.R.C., with respect to syrup and soft-drink concentrate produced by P's sec. 936, I.R.C., subsidiary, Caribbean Refrescos, Inc. 1. Held:Sec. 1.936-6(b)(1), Q&A-12, Income Tax Regs., governs the computation of combined taxable income with respect to sales of component concentrate to unrelated third parties. 2. Held, further,sec. 1.936-6(b)(1), Q&A-12, Income Tax Regs., requires U.S. affiliate expenses to be allocated and apportioned to the component concentrate by…
1Opinion of the Court
THE COCA-COLA COMPANY, AND INCLUDIBLE SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Coca-Cola Co. v. Commissioner
Docket No. 299-94.
United States Tax Court
106 T.C. 1; 1996 U.S. Tax Ct. LEXIS 1; 106 T.C. No. 1;
January 4, 1996, Filed
An appropriate order will be issued granting petitioner's motion for partial summary judgment.
P filed a motion for partial summary judgment relating to the computation of combined taxable income under sec. 936(h)(5)(C)(ii), I.R.C., with respect to syrup and soft-drink concentrate produced by P's sec. 936, I.R.C., subsidiary, Caribbean…
2Cases cited37 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Public Citizen v. United States Department of JusticeSupreme Court of the United States · 1989
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Bingler v. JohnsonSupreme Court of the United States · 1969
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