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.
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