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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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