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CRESTEK, INC. & SUBS. v. COMMISSIONER

Docket No. 8285-13.

149 T.C. 112 (2017)

149 T.C. No. 5

CRESTEK, INC. AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 27, 2017.

Attorney(s) appearing for the Case

Richard Joseph Sapinski, Robert Alan Stern, Jefferson H. Read, Matthew T. Noll, and John H. Dies, for petitioner.

Lisa M. Rodriguez, Paul N. Schneiderman, and Carmen N. Presinal-Roberts, for respondent.

OPINION

Petitioner is the parent of a group of companies that includes a number of controlled foreign corporations (CFCs). The Internal Revenue Service (IRS or respondent) determined that these CFCs had invested substantial amounts of untaxed earnings and profits (E&P) in "United States property" as defined in section...

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