Riggs National Corp. & Subsidiaries v. Commissioner
Court of Appeals for the D.C. Circuit
1Opinion of the Court
Opinion for the Court filed by Circuit Judge SENTELLE.
SENTELLE, Circuit Judge:
This case returns to us after decision on remand by the United States Tax Court. Riggs Bank, asserting that the Central Bank of Brazil paid taxes to the Brazilian government on its behalf with respect to interest income on loans it had made to the Central Bank, claimed foreign tax credits under section 901 of the Internal Revenue Code. The Commissioner disallowed the credits and the Tax Court denied Riggs’s petition for relief. Upon review, we conclude that official tax receipts that the Central Bank submitted on…
2Cases cited11 opinions
- United States v. Chemical Foundation, Inc.Supreme Court of the United States · 1926
- R. H. Stearns Co. v. United StatesSupreme Court of the United States · 1934
- UTAH POWER & LIGHT CO. v. PFOST, COMMISSIONER OF LAW ENFORCEMENT, Et Al.Supreme Court of the United States · 1932
- Continental Illinois Corporation, Also Known as Continental Bank Corporation, Cross-Appellee v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Seventh Circuit · 1993
- Murarka v. Bachrack Bros., IncCourt of Appeals for the Second Circuit · 1954
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- PNC Financial Services Group, Inc. v. Commissioner of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 2007
- Alston v. GeithnerDistrict Court, District of Columbia · 2013
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