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1 Hous. Bus. & Tax L.J. 1 (2001)

handle is hein.journals/houbtalj1 and id is 1 raw text is: COPYRIGHT © 2001 HOUSTON BUSINESS AND TAX LAW JOURNAL. ALL RIGHTS RESERVED. HOW TO READ TAX COURT OPINIONS* Mary Ann Cohen* It is a special privilege for me to be here today for several reasons. First, I am honored to initiate the anticipated annual lecture series sponsored by your Corporate & Taxation Law Society. Second, my earliest career choice was to be a teacher; therefore, I enjoy the opportunity to trade the courtroom for the lecture hall. Of course there is an advantage to the courtroom, where the black robe and gavel discourage too overt dissent from my viewpoint. Third, this may be an opportune time to discuss the function and structure of the United States Tax Court. It seems to me that the attention of the tax policy makers and the corporate world is focusing on the extent that so-called corporate tax shelters require special efforts to determine whether tax liabilities are being correctly reported by the business segment of the economy. In the past few years, the Court has tried and decided many cases involving reallocation of income among members of international corporate families.' More recently, you The text was presented as a speech to the Corporate & Taxation Law Society at the University of Houston Law Center on November 11, 1999, and contains material presented in earlier speeches and interviews of Judge Cohen. The footnotes were prepared and appended by the editors to assist those interested in further research of the subject matter. I Judge, U.S. Tax Court; B.S., University of California at Los Angeles, 1964; J.D., University of Southern California, 1967. Judge Cohen was in private practice in Los Angeles from 1967 to 1982, when she was appointed to the Tax Court for a fifteen-year term. She was reappointed in 1997. She was elected Chief Judge in 1996 and reelected in 1998 for a term ending May 31, 2000. 1. See generally H Group Holding, Inc. v. Commissioner, 78 T.C.M. (CCH) 533 (1999) (scrutinizing the allocation of income between Hyatt Corp., a domestic corporation, and HIC, a wholly owned subsidiary, owning and operating hotel properties outside the continental U.S.); Compaq Computer Corp. v. Commissioner, 78 T.C.M. (CCH) 20 (1999) (analyzing the allocation between Compaq and its Singapore subsidiary of income derived from printed circuit assemblies); DHL Corp. v. Commissioner, 76 T.C.M. (CCH) 1122 (1998) (examining the allocation of income among the shareholders of DHL and related foreign DHL corporations and foreign investors who became the majority shareholders in the related foreign DHL entities from a transaction involving the sale of more than 50% of the portion of the DHL network outside the U.S.); General Dynamics Corp. v. Commissioner, 108 T.C. 107 (1997) (investigating the allocation among General Dynamics and its foreign sales corporations of commission income that may be deferred or excluded under DISC or FSC); Seagate Tech., Inc. v. Commissioner, 102 T.C. 149 (1994) acq. in result, 1995-2 C.B. 1, and 1995-33 I.R.B. 4, and 1996-1 I.R.B. 5 (focusing on allocation

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