Computervision Corp. v. Commissioner
United States Tax Court
P, a manufacturer of computer products, utilized a domestic international sales corporation (DISC) as a commission agent for export sales of its products. Held, combined taxable income (CTI) of P and its DISC computed under full cost accounting must be reduced by the full amount of discount incurred on the transfer of export accounts receivable from P to its DISC.
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P, a manufacturer of computer products, utilized a domestic international sales corporation (DISC) as a commission agent for export sales of its products. Held, combined taxable income (CTI) of P and its DISC computed under full cost accounting must be reduced by the full amount of discount incurred on the transfer of export accounts receivable from P to its DISC. Dresser Industries v. Commissioner, 92 T.C. 1276 (1989), affd. in part, revd. on an unrelated issue 911 F.2d 1128 (5th Cir. 1990), followed. Held, further, discount is incorporated into the computation of CTI of P and its DISC under…
1Opinion of the Court
OPINION
NlMS, Chief Judge:
Respondent determined a deficiency in petitioner’s 1981 Federal income tax in the amount of $385,708. The issues for decision are: (1) Whether petitioner properly apportioned and allocated the discount incurred on its transfer of accounts receivable to its domestic international sales corporation (DISC) in computing the commission payable to the DISC under full cost accounting; (2) whether petitioner properly applied the discount incurred on its transfer of accounts receivable to its DISC in computing the commission payable to the DISC under marginal cost accounting…
2Cases cited13 opinions
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
- Columbian Rope Co. v. CommissionerUnited States Tax Court · 1964
- Dresser Industries, Inc. And Consolidated Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
- Thomas International Limited v. The United StatesCourt of Appeals for the Federal Circuit · 1985
8 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Computervision Int'l Corp. v. CommissionerUnited States Tax Court · 1996
- Computervision Corp. v. CommissionerUnited States Tax Court · 1992
- Computervision Corp. v. CommissionerUnited States Tax Court · 1991