Legal Opinion

Zuanich v. Commissioner

United States Tax Court

Decided August 20, 1981No. Docket No. 594-78Published

Petitioner-husband discussed with respondent's agents the availability of the foreign tax credit on account of Canadian taxes paid by a corporation of which petitioner-husband was majority shareholder. Held, the doctrine of equitable estoppel does not bar respondent from disallowing this credit ( Automobile Club of Michigan v. Commissioner, 353 U.S. 180 (1957)); this credit is not allowable.

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Petitioner-husband discussed with respondent's agents the availability of the foreign tax credit on account of Canadian taxes paid by a corporation of which petitioner-husband was majority shareholder. Held, the doctrine of equitable estoppel does not bar respondent from disallowing this credit ( Automobile Club of Michigan v. Commissioner, 353 U.S. 180 (1957)); this credit is not allowable. Petitioner-husband purchased and placed into service on his commercial fishing vessel a hydraulic fishing reel. He purchased the reel entirely with funds withdrawn from a capital construction fund…

1Opinion of the Court

Peter Zuanich and Mary Ann Zuanich, Petitioners v. Commissioner of Internal Revenue, Respondent

Zuanich v. Commissioner

Docket No. 594-78

United States Tax Court

77 T.C. 428; 1981 U.S. Tax Ct. LEXIS 72;

August 20, 1981, Filed

Decision will be entered for the respondent.

Petitioner-husband discussed with respondent's agents the availability of the foreign tax credit on account of Canadian taxes paid by a corporation of which petitioner-husband was majority shareholder. Held, the doctrine of equitable estoppel does not bar respondent from disallowing this credit ( Automobile Club of Michigan v.…

Also in this document: Concurring in part, dissenting in part.

2Cases cited44 opinions

  1. United States v. American Trucking AssociationsSupreme Court of the United States · 1940
  2. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  3. Dixon v. United StatesSupreme Court of the United States · 1965
  4. Barr v. United StatesSupreme Court of the United States · 1945
  5. Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934

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