Legal Opinion
Texasgulf Inc. and Subsidiaries, as Successor in Interest to Texasgulf Inc. and Subsidiaries v. Commissioner
United States Tax Court
Decided September 9, 1996No. 15528-89Unknown
1Opinion of the Court
107 T.C. No. 5
UNITED STATES TAX COURT TEXASGULF INC. AND SUBSIDIARIES, AS SUCCESSOR IN INTEREST TO TEXASGULF INC. AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15528-89. Filed September 9, 1996. Under the Ontario Mining Tax (OMT), mine operators are generally liable for a tax on gross receipts less deductions for several expenses and a processing allowance. P paid the OMT and claimed a foreign tax credit under sec. 901, I.R.C. P and R agree that sec. 1.901-2, Income Tax Regs., applies to the years at issue. R concedes that the OMT is a tax and that it…
2Cases cited16 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Burnet v. Chicago Portrait Co.Supreme Court of the United States · 1932
- Estate of Cora R. Fitts, Deceased, J. Russel Fitts and Frank E. Tyler, Co-Executors v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1956
- IT&S of Iowa, Inc. v. CommissionerUnited States Tax Court · 1991
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