118 T.C. No. 3
UNITED STATES TAX COURT
FRAMATOME CONNECTORS USA, INC., PRESENTLY KNOWN AS FRAMATOME
CONNECTORS USA HOLDING INC., AND SUBSIDIARIES, AND BURNDY
CORPORATION PRESENTLY KNOWN AS FRAMATOME CONNECTORS USA INC.
Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
FRAMATOME CONNECTORS USA, INC., AND SUBSIDIARIES, N.K.A.
FRAMATOME CONNECTORS USA HOLDING INC., AND SUBSIDIARIES,
Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 5030-98, 9160-99. Filed January 16, 2002.
Controlled Foreign Corporation Issue: In 1992,
Burndy-US (B-US), a predecessor of Framatome Connectors
USA, Inc., one of the petitioners (Ps), owned 50
percent of the stock of Burndy-Japan (B-J). Furukawa
Electric Co. (F) and Sumitomo Electrical Indus., Ltd.
(S), each owned 25 percent of the stock of B-J.
Ps contend that B-US owned more than 50 percent of
the voting power of B-J stock and owned more than 50
percent of the value of B-J stock, and that, as a
result, B-J was a controlled foreign corporation (CFC)
in 1992 under both sec. 957(a)(1) and (2), I.R.C.
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