First Chicago Corp. v. Commissioner
United States Tax Court
S, a domestic bank, and its related subsidiaries (consolidated affiliates) purchased shares in F, a foreign bank. The purchase was pursuant to and in connection with various agreements between S (including its subsidiaries) and F which provided for the business relationship between S and F. Under the agreements, it was intended that S and/or its subsidiaries would, in the aggregate, hold at least 10 percent of F's voting shares.
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S, a domestic bank, and its related subsidiaries (consolidated affiliates) purchased shares in F, a foreign bank. The purchase was pursuant to and in connection with various agreements between S (including its subsidiaries) and F which provided for the business relationship between S and F. Under the agreements, it was intended that S and/or its subsidiaries would, in the aggregate, hold at least 10 percent of F's voting shares. During the period in issue, S and its subsidiaries may have, in the aggregate, held 10 percent of the voting shares of F, but none of the S affiliates, at any time,…
1Opinion of the Court
First Chicago Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
First Chicago Corp. v. Commissioner
Docket No. 11174-87
United States Tax Court
96 T.C. 421; 1991 U.S. Tax Ct. LEXIS 17; 96 T.C. No. 14;
March 7, 1991, Filed
Decision will be entered under Rule 155.
S, a domestic bank, and its related subsidiaries (consolidated affiliates) purchased shares in F, a foreign bank. The purchase was pursuant to and in connection with various agreements between S (including its subsidiaries) and F which provided for the business relationship between S and F. Under the agreements, it was…
2Cases cited26 opinions
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- Helvering v. HorstSupreme Court of the United States · 1940
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
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