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General Electric Company and Subsidiaries v. Commissioner of Internal Revenue

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Argued: January 9, 2001

Appeal from a judgment of the United States Tax Court (Mary Ann Cohen, Judge) determining petitioner-appellant’s tax liabilities for the taxable years 1979 and 1980, to the extent that the judgment was based on a July 13, 1995 Memorandum Opinion entered by the United States Tax Court (David Laro, Judge). See General Elec. Co. & Subsidiaries v. Commissioner, 70 T.C.M. (CCH) 39 (1995). The 1995 Memorandum Opinion held that petitioner-appellant was not entitled to certain tax benefits under the Domestic International Sales Corporation program established by the Revenue Act of 1971, Pub. L. No. 92-178, 85 Stat. 497, because aircraft engines and thrust reversers sold by petitioner-appellant to Boeing Aircraft, Inc. (“Boeing”) and McDonnell Douglas Corporation (“MDC”), and attached by Boeing and MDC to airframes that they had produced for export, did not constitute “export property” as defined by the Act.

As to the engines, we hold (1) that the Act is, in relevant part, ambiguous, and that we must therefore defer to the pertinent regulations promulgated by the United States Department of the Treasury; and (2) that under the relevant regulations the engines were not “subject[ed] . . . to . . . assembly . . . or other processing,” Treas. Reg. � 1.993-3(d)(2)(iii) (1977), by being attached to the airframes. Accordingly, we reverse the Tax Court’s judgment as to the engines, and remand the cause for entry of judgment as to the engines in favor of petitioner-appellant.

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