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Dave Fischbein Manufacturing Co. v. Commissioner
United States Tax Court
59 T.C. 338 (1972)
- Written by Daniel Clark, JD
Facts
Compagnie Fischbein, S.A. (CFSA) was a Belgian subsidiary and controlled foreign corporation (CFC) of Dave Fischbein Manufacturing Company (DFC) (plaintiff), an American corporation. CFSA sold portable bag-closing machines, which it assembled in Belgium. In creating the bag-closing machines, CFSA used components sourced from outside Belgium. The Internal Revenue Service (IRS) (defendant) determined that CFSA’s sales of the bag-closing machines generated foreign base company sales income (FBCSI) that was taxable to DFC under Subpart F of the Internal Revenue Code (code). DFC challenged the IRS’s position in the United States Tax Court.
Rule of Law
Issue
Holding and Reasoning (Irwin, J.)
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