United States Tax Court January 8, 2020, 4816-15 (Adams Challenge (UK) Limited v. Commissioner)

154 T.C. No. 3

UNITED STATES TAX COURT

ADAMS CHALLENGE (UK) LIMITED, Petitioner v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 4816-15. Filed January 8, 2020.

P is a U.K. private limited liability company whose sole

income-producing asset for the years at issue was a multi-purpose

support vessel. The vessel was chartered by a U.S.