Legal Opinion
Taxation & Revenue Department v. F. W. Woolworth Co.
New Mexico Supreme Court
Decided January 19, 1981No. 12876PublishedCited by 7 opinions
1Opinion of the Court
OPINION
EASLEY, Chief Justice.
Woolworth appealed to the Court of Appeals a decision of the New Mexico Taxation and Revenue Department (Department) which assessed additional corporate income taxes for fiscal year 1976-77. The Court of Appeals, 95 N.M. 542, 624 P.2d 51, reversed the Department. We reverse the Court of Appeals.
There are three issues: (1) whether “gross up”, meaning the foreign income taxes paid by Woolworth’s foreign subsidiaries which Woolworth is required to report as dividend income in its federal income tax return in order to claim a tax credit for those foreign taxes paid,…
2Cases cited39 opinions
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- Wisconsin v. J. C. Penney Co.Supreme Court of the United States · 1941
- Northwestern States Portland Cement Co. v. MinnesotaSupreme Court of the United States · 1959
- Mobil Oil Corp. v. Commissioner of Taxes of Vt.Supreme Court of the United States · 1980
- Japan Line, Ltd. v. County of Los AngelesSupreme Court of the United States · 1979
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3Cited by7 opinions
- NCR Corp. v. Comptroller of the TreasuryCourt of Appeals of Maryland · 1988
- COMPTROLLER OF TREASURY, IT DIV. v. NCR Corp.Court of Special Appeals of Maryland · 1987
- Mountain States Telephone & Telegraph Co. v. New Mexico State Corp.New Mexico Supreme Court · 1986
- Sutin, Thayer & Browne v. Revenue Division of the Taxation & Revenue DepartmentNew Mexico Court of Appeals · 1984
- Rates & Charges of Mountain States Tel. & Tel.New Mexico Supreme Court · 1986
2 more not listed; retrieve them via the Exa API.