Qantas Airways Ltd. v. United States

OPINION

YOCK, Judge.

The plaintiff in this, action is an international airline owned and controlled by the Australian government. It seeks to recover over $1.8 million in income taxes it paid to the United States Government on rental and capital gains income for the tax years ending March 31, 1983, 1984, and 1985. The plaintiff alleges that this income was exempt from taxation under the former section 892 of the Internal Revenue Code (1982)1, the foreign government exemption, and the former section 883 of the Internal Revenue Code (1982), the exemption for income from the international…