United States Ninth Circuit

A temporary tax regulation governing sales between controlled group members (corporations with interlocking ownerships) was not inconsistent with 26 U.S.C. section 267(f), and did not violate the 1975 U.S.-U.K. Tax Convention.

Appellate Information

• Argued 12/04/2001
• Decided 09/18/2002
• Published 09/18/2002

Judges

• Before BRUNETTI, KLEINFELD and THOMAS, Circuit Judges.

Court

• United States Ninth Circuit

Counsel

• For Appellant:
  
• Frederick R. Chilton, Jr., Paolo M. Dau, and Ward S. Connelly (on the brief), Paulo Dau (argued), Fenwick & West LLP, Palo Alto, CA, for the petitioner.


• For Appellees:
  
• Jonathan S. Cohen and Charles Bricken (on the brief), Charles Bricken (argued), Department of Justice, Tax Division, Washington, DC, for the respondent.