United States Tax Court June 25, 1997, Docket 10159-95 (Taiyo Hawaii Company, Ltd. v. Commissioner)

108 T.C. No. 27

UNITED STATES TAX COURT

TAIYO HAWAII COMPANY, LTD., Petitioner v. COMMISSIONER

OF INTERNAL REVENUE, Respondent

Docket No. 10159-95. Filed June 25, 1997.

P, a foreign corporation wholly owned by a foreign

conglomerate, was engaged in real estate activity in

Hawaii. P borrowed funds from foreign banks and also

received advances from its parent and a related foreign

corporation.