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PACIFIC BASIN MFG. & TRADE CO. v. C. I. R.

No. 82-7564.

716 F.2d 638 (1983)

PACIFIC BASIN MANUFACTURING & TRADE COMPANY, LTD., a corporation, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided September 20, 1983.

Attorney(s) appearing for the Case

Patrick H. Fabian, Robert S. Lyons, Cullinan & Lyons, San Francisco, Cal., for petitioner-appellant.

Michael L. Paup, Glenn L. Archer, Washington, D.C., for respondent-appellee.

Before TRASK, SNEED and FARRIS, Circuit Judges.

PER CURIAM:

Taxpayer appeals from a Tax Court judgment holding it liable for income tax deficiencies for tax years ending June 30, 1975 and 1976. We affirm.

I.

FACTS

Taxpayer is a Delaware corporation that maintains its sole manufacturing facility and its principal office in American Samoa, a United States possession. It manufactures jewelry and in 1975 and 1976 the bulk of its sales was to its parent, Edward D. Sultan Co., Ltd., a Hawaii...

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