- 3 -
certain interest owed to related foreign persons during the
taxable years in which the interest was accrued but not paid.1
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect for taxable years 1991 and 1992,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
Factual Background
The facts have been stipulated by the parties and are so
found. We incorporate by this reference the stipulation of
facts, the first supplemental stipulation of facts, and
accompanying exhibits. The following summary of the facts is
based on the stipulations.
Square D Company, a Delaware corporation with its principal
executive offices in Palatine, Illinois, is the common parent of
an affiliated group of corporations making a consolidated return
(collectively, petitioner). Petitioner computes consolidated
taxable income on the basis of a calendar year.
Prior to its acquisition by Schneider S.A. (discussed
below), petitioner was a publicly held company whose stock was
traded on the New York Stock Exchange. During the years in issue
petitioner was engaged in the United States and abroad in the
manufacture and sale of electrical distribution and industrial
1 Other issues raised in the instant case are considered in
a separate opinion.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011