Long v. Commissioner
United States Tax Court
Held: Respondent entered into a closing agreement with petitioner and his two controlled corporations, Manufacturing and Specialty, whereby income was allocated to Manufacturing from Specialty pursuant to sec. 482. Petitioner and the corporations elected the relief available under Rev. Proc. 65-17, 1965-1 C.B. 833. Pursuant to that election, Manufacturing and Specialty set up an account receivable and an account payable, respectively, in an amount equal to the sec. 482…
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Held: Respondent entered into a closing agreement with petitioner and his two controlled corporations, Manufacturing and Specialty, whereby income was allocated to Manufacturing from Specialty pursuant to sec. 482. Petitioner and the corporations elected the relief available under Rev. Proc. 65-17, 1965-1 C.B. 833. Pursuant to that election, Manufacturing and Specialty set up an account receivable and an account payable, respectively, in an amount equal to the sec. 482 allocation. Pursuant to the closing agreement, the account receivable was to be satisfied within 90 days after the…
1Opinion of the Court
William R. Long, Petitioner v. Commissioner of Internal Revenue, Respondent
Long v. Commissioner
Docket No. 36064-87
United States Tax Court
93 T.C. 5; 1989 U.S. Tax Ct. LEXIS 98; 93 T.C. No. 2;
July 11, 1989; As corrected July 19, 1989 July 11, 1989, Filed
Decision will be entered for the respondent.
Held: Respondent entered into a closing agreement with petitioner and his two controlled corporations, Manufacturing and Specialty, whereby income was allocated to Manufacturing from Specialty pursuant to sec. 482. Petitioner and the corporations elected the relief available under Rev. Proc. 65-17,…
2Cases cited11 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Richard Rubin and Helene Rubin v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970
- United States v. LaneCourt of Appeals for the Fifth Circuit · 1962
- Paccar, Inc. And Subsidiaries v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
- Bausch & Lomb, Inc. v. CommissionerUnited States Tax Court · 1989
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