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CAMPBELL TAGGART, INC. v. UNITED STATES

No. CA 3-80-0968-C.

552 F.Supp. 355 (1982)

CAMPBELL TAGGART, INC. v. UNITED STATES of America.

United States District Court, N.D. Texas, Dallas Division.

December 1, 1982.

Attorney(s) appearing for the Case

Neil J. O'Brien, Pamela Hobgood Wiese, Gardere & Wynne, Dallas, Tex., for plaintiff.

William W. Guild, Atty. in Charge, Johnny D. Mixon, Atty., Tax Div., Dept. of Justice, Dallas, Tex., Roger M. Moore, Atty. (Southern Region), Tax Div., Dept. of Justice, Washington, D.C., James A. Rolfe, U.S. Atty., Martha Joe Stroud, Asst. U.S. Atty., Dallas, Tex., for defendant.

CORRECTED OPINION

WILLIAM M. TAYLOR, Jr., District Judge.

This is an income tax case which the parties have agreed is of first and last impression.

Plaintiff is a Delaware corporation with its principal place of business in Dallas, Texas. It is a holding company that mainly derives its income from service fees and dividends paid by its 60 domestic and three foreign subsidiaries. These subsidiaries produce...

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