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U.S. PADDING CORP. v. C.I.R.

No. 87-2211.

865 F.2d 750 (1989)

U.S. PADDING CORP., Petitioner-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Sixth Circuit.

Decided January 12, 1989.

Attorney(s) appearing for the Case

Gary R. Allen, Tax Div., Dept. of Justice, Washington, D.C., Nancy G. Morgan, Gilbert S. Rothenberg (argued), for respondent-appellant.

Paul R. Jackman, Harper Woods, Mich., Meyer & Kirk, Bloomfield Hills, Mich., Robert H. Aland (argued), Karen A. Kuenster, Maurice S. Emmer, Francis D. Morrissey, William Lynch Schaller, Baker & McKenzie, Chicago, Ill., for petitioner-appellee.

Before WELLFORD and BOGGS, Circuit Judges; and SIMPSON, District Judge.

BOGGS, Circuit Judge.

The Commissioner appeals a decision of the United States Tax Court, which concluded that U.S. Padding Corp.'s (USPC's) wholly owned subsidiary, Trans Canada Non Woven, Ltd. (Trans Canada), was incorporated in Canada for the sole purpose of complying with Canadian laws pursuant to the Foreign Investment Review Act (FIRA). Thus, Trans Canada was eligible to file a consolidated tax return with USPC pursuant to 26 U.S.C. § 1504(d). We affirm...

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