Zuanich v. Commissioner
United States Tax Court
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 He purchased the reel entirely with funds withdrawn from a capital construction fund…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
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Dixon v. United StatesSupreme Court of the United States · 1965
- Barr v. United StatesSupreme Court of the United States · 1945
- Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
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