108 T.C. No. 17 UNITED STATES TAX COURT ROBERT A. STANFORD AND SUSAN STANFORD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 103-94. Filed April 29, 1997. Held: For 1990, (1) subpart F income of a controlled foreign corporation may not be reduced by deficits in earnings and profits of a controlled foreign sister corporation; and (2) on the particular facts of this case, subpart F income of a controlled foreign corporation may not be reduced by deficits in earnings and profits of a controlled foreign parent corporation. Salvador E. Rodriguez and Maxime Louis Bouthillette, for petitioners. Lillian D. Brigman and Susan Sample, for respondent.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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