Legal Opinion

CCA, Inc. v. Commissioner

United States Tax Court

Decided May 6, 1975No. Docket Nos. 6524-71, 3628-72Published

P corporation established S as a wholly owned foreign subsidiary. Upon passage of the Revenue Act of 1962, preferred stock of S was issued to non-United States shareholders possessing 50 percent of the voting power. There were no substantial restrictions placed on the preferred stock and representatives on the board of directors had significant powers which could be utilized to alter the course of events of S. Held, S is not a controlled foreign corporation.

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P corporation established S as a wholly owned foreign subsidiary. Upon passage of the Revenue Act of 1962, preferred stock of S was issued to non-United States shareholders possessing 50 percent of the voting power. There were no substantial restrictions placed on the preferred stock and representatives on the board of directors had significant powers which could be utilized to alter the course of events of S. Held, S is not a controlled foreign corporation. Sec. 957(a), I.R.C. 1954.

1Opinion of the Court

CCA, Inc. (Formerly Controls Company of America, Transferor, an Illinois Corporation), Controls Company of America (Formerly Catherine Corporation, Transferee, a Delaware Corporation), Petitioners v. Commissioner of Internal Revenue, Respondent; The Singer Company, as Successor by Merger to General Precision Equipment Corporation and Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent

CCA, Inc. v. Commissioner

Docket Nos. 6524-71, 3628-72

United States Tax Court

64 T.C. 137; 1975 U.S. Tax Ct. LEXIS 155;

May 6, 1975, Filed

Decisions will be entered under Rule 155.

P corporation…

2Cases cited6 opinions

  1. Garlock, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1973
  2. Garlock, Inc. v. CommissionerUnited States Tax Court · 1972
  3. Kraus v. CommissionerUnited States Tax Court · 1973
  4. Estate of Weiskopf v. CommissionerUnited States Tax Court · 1975
  5. Hans P. Kraus and Hanni Z. Kraus v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1974

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