Gibbons Int'l v. Commissioner
United States Tax Court
Held, petitioner Gibbons International does not qualify as a Domestic International Sales Corporation because commissions receivable due from its domestic parent corporation were not "paid" within the meaning of sec. 1.994-1(e)(3), Income Tax Regs.
1Opinion of the Court
SWIFT, Judge:
In statutory notices of deficiency dated April 2, 1985, respondent determined deficiencies in the 1978 through 1981 Federal income tax liabilities of petitioner Gibbons International, Inc., and deficiencies in and additions to the 1977 through 1980 Federal income tax liabilities of petitioner J.T. Gibbons, Inc., in the following amounts:
PETITIONER Gibbons INTERNATIONAL, Inc. Docket No. 22469-85
TYE July 31 Deficiency
1978 ... $66,001
1979 ... 102,229
1980 ... 120,676
1981 ... 65,650
PetitioneR J.T. Gibbons, Inc. Docket No. 22470-85
Addition to tax
Year Deficiency sec. 6651(a)(1)1
1977…
2Cases cited11 opinions
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Marcello v. CommissionerUnited States Tax Court · 1964
- Westinghouse Electric Corp. v. TullySupreme Court of the United States · 1984
- Cwt Farms, Inc. And Cwt International, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
- CWT Farms, Inc. v. CommissionerUnited States Tax Court · 1982
6 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
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- Rocky Mountain Associates International, Inc. v. CommissionerUnited States Tax Court · 1988
- Jet Research, Inc. v. CommissionerUnited States Tax Court · 1990
- Addison International, Inc. v. CommissionerUnited States Tax Court · 1988
6 more not listed; retrieve them via the Exa API.