Opinion
No. 13–P–984.
2014-06-18
ALLIED DOMECQ SPIRITS & WINES USA, INC. v. COMMISSIONER OF REVENUE.
An August 22, 1996, e-mail described the undertaking as a “state tax planning project.” It pushed for implementation by the end of the month in order to include ADNAC in the August, 1996, return and noted that the plan would have “no impact to the management results .” Finally, an August 26, 1996, memo laid out plans to bill ADNAC for the salaries of several Dunkin' Donuts employees, sell Dunkin' Donuts office furniture and equipment to ADNAC, and charge rent to ADNAC for space in the Dunkin' Donuts office, including rent for the month already underway. The memo urged that “[t]he foregoing transactions should be implemented by August 31, 1996 to realize the full group tax benefit estimated at $500,000 (after Federal benefit) for FY1996.”