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A Problem of Remedy:Responding to Treasury's (Lack of

See, e.g., Boeing Co. v. United States, 537 U.S. 437, 446 (2003) (outlining dispute over 136, 145 n.3 (6th Cir. 2003) (noting taxpayer's failure to raise potential APA procedural claims in challenging validity of temporary Treasury regulations and thus declining to consider the issue). BOEING CO. v. U.S. 1099BOEING CO. v. U.S. 1101 Cite as 123 S.Ct. 1099 (2003) 537 U.S. 438 parties aggregate income from export sales. The statute provides three alterna-tive ways for a parent to divert a limited portion of its income to the DISC. See §§ 994(a)(1)-(3). The alternative that The Boeing Company chose limited the DISCs taxable income to a little over half of the

BOEING CO. v. UNITED STATES FindLaw

  • IIIIV* * *Boeing also advances two arguments based on the text of specific DISC regulations. The first resembles its argument based on the text of §861 and the second relies on regulations providing that certain accounting decisions made by the taxpayer shall be controlling. The regulations included in 26 CFR §1.994-1 (1979) set forth intercompany pricing rules for DISCs. They generally describe the three methods of determining a transfer price, noting that the taxpayer may choose the most favorable methoCite as:537 U. S. (2003) 1 T SUPREME COURT OF THE cite as:537 u. s. ____ (2003) 1 thomas, j., dissenting supreme court of the united states _____ nos. 011209 and 012 _____ the boeing company and consolidated subsidiaries, petitioners 011209 v. united states united states, petitioner 012 v. boeing sales corporation et al. on writs of certiorari to the united states court of Boeing Company v. United States - Case Briefs - 2002PETITIONER:Boeing Company RESPONDENT:United StatesLOCATION:Dr. Nguyens Office. DOCKET NO.:01-1209 DECIDED BY:Rehnquist Court (1986-2005) LOWER COURT:United States Court of Appeals for the Ninth Circuit. CITATION:537 US 437 (2003) ARGUED:Dec 09, 2002 DECIDED:Mar 04, 2003. ADVOCATES:Kenneth Steven Geller Argued the cause for the petitioner In the Supreme Court of the United States2010 Bachman Legal Printing (612) 339-9518 1-800-715-3582 Fax (612) 337-8053 No. 09-837 In the Supreme Court of the United States _____ Mayo Foundation for Medical Education and Research; Mayo Clinic; and Regents of the

    In the United States Court of Federal Claims

    Boeing Co. v. United States, 537 U.S. 437, 456 (2003) (citing S. Rep. No. 92-437 at 13 (1971)). A qualifying FSC, as defined in 26 U.S.C. § 922 (1994), was permitted to treat No. 07-636 In the Supreme Court of the United StatesJan 01, 2007 · no. 07-636 in the supreme court of the united states kari e. kennedy, petitioner v. plan administrator for dupont savings and investment plan, et al. on writ of certiorari to the united states court of appeals for the fifth circuit brief for the united states as TABLE OF CONTENTSDevelopment v. Rucker, 535 U.S. 125, 133 (2002) (when Congress amends a statute but does not indicate any change to a particular aspect of prior law, that aspect remains in place); Boeing Co. v. United States, 537 U.S. 437, 456 (2003) (same); Lorillard v. Pons, 434 U.S. 575, 580-581 (1978) (same). Currently, as previously, CRIPAs exhaustion provi-

    U.S. Reports:Moseley et al., dba Victor's Little Secret v

    Title U.S. Reports:Moseley et al., dba Victor's Little Secret v. V Secret Catalogue, Inc., et al., 537 U.S. 418 (2003). Contributor Names UNITED STATES COURT OF APPEALS FOR THE NINTH Jun 02, 2021 · 16702- 09 . 16779- 09 . OPINION . Appeal from a Decision of the . United States Tax Court . Argued and Submitted February 14, 2020 . Pasadena, California United States Court of Appeals for the Federal Circuitstatute of limitations on assessment. Abbott, 84 Fed. Cl. at 107; see also Boeing Co. v. United States, 537 U.S. 437, 456 (2003) ([E]ven though the purpose of the DISC and FSC statutes was to provide American firms with a tax incentive to increase their exports, Congress did not intend to grant undue tax advantages to firms. Rather, the

    Volume 537 - United States Supreme Court - United States

    Boeing Co. v. United States, 537 U.S. 437 (2003) United States v. White Mountain Apache Tribe, 537 U.S. 465 (2003) United States v. Navajo Nation, 537 U.S. 488 (2003) Clay v. United States, 537 U.S. 522 (2003) Chabad of Southern Ohio v. Cincinnati, 537 U.S. 1501 (2002) Last modified:August 29, 2013. State Laws. Alabama Alaska Arizona CaliforniaBOEING CO. V. UNITED STATESBOEING CO. V. UNITED STATES (01-1209) 537 U.S. 437 (2003) 258 F.3d 958, affirmed. Syllabus Opinion [ Stevens ] Dissent [ Thomas ] HTML version PDF version:HTML version PDF version:HTML version PDF version