Globe Products Corp. v. Commissioner
United States Tax Court
T, an accrual basis taxpayer, is a former member of an affiliated group of corporations that filed consolidated returns. In 1968, T and several other former affiliates entered into an agreement (sharing agreement) to share payment of potential Federal income tax liabilities and interest that might subsequently be determined to be owed by the affiliated group for earlier consolidated return years.
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T, an accrual basis taxpayer, is a former member of an affiliated group of corporations that filed consolidated returns. In 1968, T and several other former affiliates entered into an agreement (sharing agreement) to share payment of potential Federal income tax liabilities and interest that might subsequently be determined to be owed by the affiliated group for earlier consolidated return years. On Aug. 1, 1972, a stipulated decision was entered by this Court finding deficiencies in Federal consolidated income tax for 1961 and 1962 against the affiliated group. Pursuant to the sharing…
1Opinion of the Court
Globe Products Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Globe Products Corp. v. Commissioner
Docket No. 9070-75
United States Tax Court
72 T.C. 609; 1979 U.S. Tax Ct. LEXIS 94;
July 5, 1979, Filed
Decision will be entered under Rule 155.
T, an accrual basis taxpayer, is a former member of an affiliated group of corporations that filed consolidated returns. In 1968, T and several other former affiliates entered into an agreement (sharing agreement) to share payment of potential Federal income tax liabilities and interest that might subsequently be determined to be owed…
2Cases cited18 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- Helvering v. Russian Finance & Construction CorporationCourt of Appeals for the Second Circuit · 1935
- Baltimore Transfer Co. v. CommissionerUnited States Tax Court · 1947
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