ADDISON INTERN., INC. v. C.I.R.

No. 89-1003.

887 F.2d 660 (1989)

ADDISON INTERNATIONAL, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided October 10, 1989.

Rehearing Denied November 6, 1989.


Attorney(s) appearing for the Case

Joseph M. Persinger, New York City, F. David Lake, Jr., Wilmer, Cutler & Pickering, Washington, D.C., Timothy G. Reaume, Dickinson, Wright, Moon, Van Dusen & Freeman, Detroit, Mich., Michael D. Horlick (argued), Venice, Fla., for petitioner-appellant.

Peter K. Scott, I.R.S., Gary R. Allen, Acting Chief, Robert A. Bernstein, Michael J. Roach (argued), U.S. Dept. of Justice, Tax Div., Washington, D.C., for respondent-appellee.

Before KEITH and MARTIN, Circuit Judges; ENGEL, Senior Circuit Judge.


BOYCE F. MARTIN, Jr., Circuit Judge.

Addison International appeals the tax court's two-part decision in Addison International, Inc. v. Commissioner, 90 T.C. 1207 (1988), holding (1) that Addison International failed to qualify as a Domestic International Sales Corporation under §§ 991-997 of the Internal Revenue Code (1954) for the taxable year of 1977, and (2) that Addison International was the proper taxpayer with...

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