Hongkong & Shanghai Banking Corp. v. Commissioner
United States Tax Court
Petitioner (P) is a Hong Kong corporation primarily engaged in the banking business, worldwide. During the years in issue, P had assets and operations in virtually every western nation, including U.S. branch offices in New York, Chicago, and Seattle. P timely filed Forms 1120F (U.S.
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Petitioner (P) is a Hong Kong corporation primarily engaged in the banking business, worldwide. During the years in issue, P had assets and operations in virtually every western nation, including U.S. branch offices in New York, Chicago, and Seattle. P timely filed Forms 1120F (U.S. Income Tax Return of a Foreign Corporation) for the years 1974, 1975, and 1976. Upon audit of the returns, the Commissioner (R) disallowed certain interest and office administrative deductions for lack of substantiation on the ground that R's agents had been denied access to P's original books and records in Hong…
1Opinion of the Court
OPINION
Nims, Judge:
This matter is before the Court on respondent’s motion for an order under section 7456(b)1 to require petitioner to produce in Court certain books and records located in its home office in Hong Kong. Respondent determined deficiencies in petitioner’s Federal income tax as follows:
Year ended Dec. 31— Deficiency
1972. $38,651
1975. 142,156
The deficiencies result from adjustments made by respondent on petitioner’s 1974, 1975, and 1976 Forms 1120F returns.
Two issues2 remaining in the case which are relevant to the motion under consideration are (1) whether petitioner is entitled…
2Cases cited7 opinions
- United States v. PowellSupreme Court of the United States · 1964
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Alan B. Karme and Laila M. Karme v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
- Karme v. CommissionerUnited States Tax Court · 1980
- United States v. Arthur Young & Company, and Amerada Hess Corporation, Intervenor-Respondent-AppellantCourt of Appeals for the Second Circuit · 1982
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3Cited by7 opinions
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- Gerling Int'l Ins. Co. v. CommissionerUnited States Tax Court · 1992
- Flying Tigers Oil Co. v. CommissionerUnited States Tax Court · 1989
- Flying Tigers Oil Co. v. CommissionerUnited States Tax Court · 1989
- Gerling Int'l Ins. Co. v. CommissionerUnited States Tax Court · 1992
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