MedChem, Inc. v. Comm'r
2001 U.S. Tax Ct. LEXIS 26 | United States Tax Court | 2001
Holding Summary
MedChem P.R. does not meet the active conduct of a trade or business requirement under IRC Section 936(a)(2)(B) because it lacked sufficient independent operations and control over manufacturing.
We hold it does not meet the active conduct requirement.
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