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James P. Fuller, Kenneth B. Clark, and David L. Forst, for
petitioner.
Nancy B. Herbert, Ruth M. Spadaro, and Jeffrey L. Bassin,
for respondent.
OPINION
LARO, Judge: This matter is before the Court on cross-
motions for partial summary judgment. See Rule 121.1 Petitioner
petitioned the Court to redetermine respondent’s determination of
deficiencies of $5,083,201, $1,783,938, $244,211, $1,152,171,
$14,011,513, and $68,811 in its Federal income tax for its
taxable years ended January 2, 1988, December 31, 1988, December
30, 1989, December 29, 1990, December 28, 1991, and January 2,
1993, respectively.
Following our disposition of the other issue in this case,
see Textron Inc. & Sub. Cos. v. Commissioner, 115 T.C. 104
(2000), we must decide whether petitioner’s 1989 through 1992
income includes the “subpart F income” (defined infra p. 12) of
Avdel PLC (Avdel), a controlled foreign corporation (CFC). We
hold it does.
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
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