Kappus v. Commissioner
Court of Appeals for the D.C. Circuit
1Opinion of the Court
Opinion for the court filed by Circuit Judge GARLAND.
GARLAND, Circuit Judge:
Tom and Louise Kappus, United States citizens living in Canada, appeal from a decision of the United States Tax Court denying their challenge to a notice of deficiency in their federal income tax issued by -the Commissioner of Internal Revenue. The Kappuses claimed a credit against their U.S. tax for all of the taxes they paid to Canada on their Canadian-source income, leaving them with no U.S. tax liability. The Commissioner argues that section 59(a)(2) of the Internal Revenue Code, 26 U.S.C. § 59(a)(2), limits the…
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