PPG Indus., Inc. v. Commissioner
United States Tax Court
Held, respondent's allocation under sec. 482 of the Internal Revenue Code of 1954 of a substantial portion of the sales income of a Swiss subsidiary in 1960 and 1961 to its domestic parent, a manufacturer of glass, paint, and chemical products, is not sustained; held, further, the existence of a long-standing interest-free indebtedness from a Brazilian subsidiary to its domestic parent did not justify the allocation of a portion of the subsidiary's income (dividends,…
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Held, respondent's allocation under sec. 482 of the Internal Revenue Code of 1954 of a substantial portion of the sales income of a Swiss subsidiary in 1960 and 1961 to its domestic parent, a manufacturer of glass, paint, and chemical products, is not sustained; held, further, the existence of a long-standing interest-free indebtedness from a Brazilian subsidiary to its domestic parent did not justify the allocation of a portion of the subsidiary's income (dividends, interest, and gains from the sale of bonds) to the parent in 1960 under sec. 482 of the Internal Revenue Code of 1954; held,…
1Opinion of the Court
MulRONey, Judge:
This case involves income tax deficiencies determined by respondent for the years 1960 and 1961 in the respective amounts, of $2,811,000.86 and $2,681,387.67 and additional deficiencies in income tax claimed by respondent by amendments to his answer in the amounts, of $300,564 and $324,194 for the years 1960 and 1961, respectively. Concessions involving several issues have been made by both parties. The remaining issues before this Court are (1) whether respondent correctly allocated income in 1960 and 1961 to petitioner from Pittsburgh Plate Glass International S.A.…
2Cases cited28 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
- Malat v. RiddellSupreme Court of the United States · 1966
- Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
- Grenada Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
23 more not listed; retrieve them via the Exa API.
3Cited by56 opinions
- Charles A. Sammons, Individually, and Estate of Rosine S. Sammons, Deceased, Charles A. Sammons, Independent v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1973
- Eli Lilly & Company and Subsidiaries, Cross-Appellees v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Seventh Circuit · 1988
- Joseph Lupowitz Sons, Inc. v. CommissionerCourt of Appeals for the Third Circuit · 1974
- Latham Park Manor, Inc. v. CommissionerUnited States Tax Court · 1977
- Bausch & Lomb, Inc. v. CommissionerUnited States Tax Court · 1989
51 more not listed; retrieve them via the Exa API.