L & F INTERN. SALES CORP. v. U.S.

No. 88-6730.

912 F.2d 377 (1990)

L & F INTERNATIONAL SALES CORPORATION, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided August 28, 1990.


Attorney(s) appearing for the Case

John E. Breckenridge, Stradling, Yocca, Carlson & Rauth, Newport Beach, Cal., for plaintiff-appellant.

David English Carmack, Dept. of Justice, Tax Div., Washington, D.C. for defendant-appellee.

Before NELSON, NORRIS and O'SCANNLAIN, Circuit Judges.


O'SCANNLAIN, Circuit Judge:

In this federal income tax case involving eligibility for preferable treatment to a domestic international sales corporation, the question presented is whether an intercorporate payment should have been made within sixty days (as prescribed by the Secretary of the Treasury) or within two and one-half months (as contended by the taxpayer).

I

A

Before we turn to the facts in this appeal from judgment dismissing...

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