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COMMUNICATIONS SATELLITE CORP. v. U. S.

No. 155-78.

625 F.2d 997 (1980)

COMMUNICATIONS SATELLITE CORPORATION v. The UNITED STATES.

United States Court of Claims.

April 2, 1980.

Attorney(s) appearing for the Case

Harold J. Heltzer, Washington, D. C., attorney of record, for plaintiff. Crowell & Moring, Washington, D. C., of counsel.

Bruce W. Reynolds, with whom was Asst. Atty. Gen. M. Carr Ferguson, Washington, D. C., for defendant. Theodore D. Peyser, Jr. and Robert S. Watkins, Washington, D. C., of counsel.

Before FRIEDMAN, Chief Judge, COWEN, Senior Judge, and NICHOLS, Judge.

OPINION

FRIEDMAN, Chief Judge.

The plaintiff in this case is a member of the International Telecommunications Satellite Consortium (INTELSAT), an international joint venture (deemed a partnership for federal tax purposes) that operates a global commercial communications satellite system. The issue is the federal tax treatment of certain monetary distributions made by INTELSAT to its members, including the plaintiff, reflecting payments by new members required...

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