United States DC Circuit

A taxpayer fails to prove that the purpose behind its transaction with a foreign corporation is to achieve tax savings permitted by a foreign government where arguments to the Tax Court are essentially based upon hearsay and lack documentary support.

Appellate Information

• Argued 03/13/2001
• Decided 06/08/2001
• Published 06/08/2001

Judges

• Before:  SENTELLE, TATEL and GARLAND, Circuit Judges.

Court

• United States DC Circuit

Counsel

• For Appellant:
  
• James P. Fuller argued the cause for appellant.   With him on the briefs were David L. Forst, Kenneth B. Clark and William F. Colgin.


• For Appellees:
  
• Kenneth W. Rosenberg, Attorney, U.S. Department of Justice, argued the cause for appellee.   With him on the brief was Jonathan S. Cohen, Attorney.  Edward T. Perelmuter, Attorney, entered an appearance.