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ADAMS CHALLENGE (UK) LTD. v. COMMISSIONER

Docket No. 4816-15.

154 T.C. 37 (2020)

154 T.C. No. 3

ADAMS CHALLENGE (UK) LIMITED, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 8, 2020.

Attorney(s) appearing for the Case

Andrius R. Kontrimas and Robert C. Morris , for petitioner.

William D. White , Richard A. Rappazzo , and Russell S. Shieldes , for respondent.

OPINION

Petitioner is a company incorporated under the laws of the United Kingdom (U.K.). For the tax years at issue petitioner's only income-producing asset was a multi-purpose support vessel. A U.S. firm chartered petitioner's vessel to perform work decommissioning oil and gas wells and removing hurricane-related debris...

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