Edison Bros. Stores v. Commissioner
United States Tax Court
P was assessed countervailing duties by the Department of Commerce. P contested the imposition of these duties but, on Dec. 27, 1985, transferred $ 11,518,106 in trust for the sole purpose of the contingent payment of its obligations on these contested duties.
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P was assessed countervailing duties by the Department of Commerce. P contested the imposition of these duties but, on Dec. 27, 1985, transferred $ 11,518,106 in trust for the sole purpose of the contingent payment of its obligations on these contested duties. P did not inform the United States, and the United States was not aware, of the existence of the trust during 1985. P deducted the transferred amount on its 1985 Federal income tax return pursuant to sec. 461(f), I.R.C.Held, the amount transferred to the trust with respect to the Brazilian countervailing duty satisfied the requirements…
1Opinion of the Court
EDISON BROTHERS STORES, INC. AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Edison Bros. Stores v. Commissioner
Docket No. 26644-93
United States Tax Court
T.C. Memo 1995-262; 1995 Tax Ct. Memo LEXIS 263; 69 T.C.M. (CCH) 2897;
June 14, 1995, Filed
Decision will be entered under Rule 155.
P was assessed countervailing duties by the Department of Commerce. P contested the imposition of these duties but, on Dec. 27, 1985, transferred $ 11,518,106 in trust for the sole purpose of the contingent payment of its obligations on these contested duties. P did not inform the…
2Cases cited12 opinions
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- United States v. Consolidated Edison Co. of NYSupreme Court of the United States · 1961
- Consolidated Freightways, Inc. & Affiliates v. CommissionerUnited States Tax Court · 1980
- Poirier & McLane Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Poirier & McLane Corp. v. CommissionerUnited States Tax Court · 1975
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