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petitioner, a corporation that was an inhabitant of the United
States Virgin Islands (USVI) within the meaning of section 28(a)
of the Revised Organic Act of the Virgin Islands (Revised Organic
Act), 48 U.S.C. sec. 1642 (1994), was required to pay tax to the
United States on its worldwide income.
Summary judgment may be granted if the pleadings and other
materials demonstrate that no genuine issue exists as to any
material fact and that a decision may be entered as a matter of
law. See Rule 121(b); Sundstrand Corp. v. Commissioner, 98 T.C.
518, 520 (1992), affd. 17 F.3d 965 (7th Cir. 1994). Partial
summary judgment may be granted with regard to a single issue if
the conditions for summary judgment are otherwise satisfied,
notwithstanding that all of the issues in the case are not
concluded. See Rule 121(b); U.S. Bancorp v. Commissioner, 111
T.C. 231, 236 (1998). The record shows and the parties do not
dispute that there is no genuine issue as to any material fact
with respect to the issue presented by the parties' motions for
partial summary judgment. Accordingly, we may render judgment on
the issue as a matter of law. See Rule 121(b).
For the purpose of ruling on the parties' motions, we adopt
the following facts set forth in the parties' moving papers.
Petitioner was incorporated in Delaware on January 23, 1984. At
the time it filed its petition in the instant case, petitioner's
principal place of business was in Carson City, Nevada. During
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