International Telephone & Telegraph Corp. v. Commissioner

This is an appeal and a cross-appeal from a decision of the United States Tax Court, Theodore Tannenwald, Chief Judge, concerning an alleged income tax deficiency of $885,064 for the taxable year 1965 assessed by the Commissioner of Internal Revenue against International Telephone and Telegraph Corporation and its affiliated companies (ITT Group). The Tax Court rejected the asserted deficiency, and held that there had been a tax overpayment by the consolidated ITT Group of $159,689.76 for 1965. The opinion and supplemental opinion of the Tax Court are reported at 77 T.C. 60 (1981) and 77 T.C.…