Legal Opinion

Schering Corp. v. Commissioner

United States Tax Court

Decided January 23, 1978No. Docket No. 8831-75Published

T, a United States corporation, owned all of the stock of S, a Swiss corporation. On audit of T's Federal Corporate income tax returns for 1961-63, the Commissioner exercised his authority under section 482, I.R.C. 1954, to reallocate to T certain income which S had reported as its income, and on which S had paid Swiss income taxes. The reallocated income represented a portion of certain royalties and amounts received by S pursuant to licensing agreements.

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T, a United States corporation, owned all of the stock of S, a Swiss corporation. On audit of T's Federal Corporate income tax returns for 1961-63, the Commissioner exercised his authority under section 482, I.R.C. 1954, to reallocate to T certain income which S had reported as its income, and on which S had paid Swiss income taxes. The reallocated income represented a portion of certain royalties and amounts received by S pursuant to licensing agreements. Similar reallocations were made to T in respect of income received by a Swiss sales corporation that was wholly owned by S. The…

1Opinion of the Court

Schering Corporation and Subsidiaries, Petitioners v. Commissioner of Internal Revenue, Respondent

Schering Corp. v. Commissioner

Docket No. 8831-75

United States Tax Court

69 T.C. 579; 1978 U.S. Tax Ct. LEXIS 191;

January 23, 1978, Filed

Decision will be entered under Rule 155.

T, a United States corporation, owned all of the stock of S, a Swiss corporation. On audit of T's Federal Corporate income tax returns for 1961-63, the Commissioner exercised his authority under section 482, I.R.C. 1954, to reallocate to T certain income which S had reported as its income, and on which S had paid Swiss…

2Cases cited36 opinions

  1. Eisner v. MacOmberSupreme Court of the United States · 1920
  2. Graves v. New York Ex Rel. O'KeefeSupreme Court of the United States · 1939
  3. Biddle v. CommissionerSupreme Court of the United States · 1938
  4. Blair v. Oesterlein MacHine Co.Supreme Court of the United States · 1927
  5. United States v. VermontSupreme Court of the United States · 1964

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