Legal Opinion

International Telephone & Telegraph Corp. v. United States

United States Court of Claims

Decided October 17, 1979No. 214-76PublishedCited by 11 opinions

1Opinion of the CourtSmith, Judge

This case comes before us, pursuant to Rule 134(b) of this court, on the parties’ stipulated facts, and after oral argument. The controversy arises in the context of subchapter N of chapter 1 of the Internal Revenue Code of 1954 (code). Plaintiffs, who elected to file a consolidated federal income tax return for the calendar year 1962, pursuant to sections 1501 et seq. of the code, also elected to claim a foreign tax credit against United States income tax pursuant to sections 901 and 902 of the code, subject to the overall limitation on the foreign tax credit provided by section 904(a)(2) of…

2Cases cited15 opinions

  1. Massachusetts v. United StatesSupreme Court of the United States · 1948
  2. Bromley v. McCaughnSupreme Court of the United States · 1929
  3. Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
  4. American Standard, Inc. v. United StatesUnited States Court of Claims · 1979
  5. Union Electric Company of Missouri v. The United StatesUnited States Court of Claims · 1962

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3Cited by11 opinions

  1. Centex Corp. v. United StatesCourt of Appeals for the Federal Circuit · 2005
  2. In Re Prudential Lines Inc.Court of Appeals for the Second Circuit · 1991
  3. Adnan Awad, and Lynn Awad v. United States and Allen Maxwell, Ed Needham, and Dana Dickson, in Their Individual CapacitiesCourt of Appeals for the Federal Circuit · 2002
  4. International Tel. & Tel. Corp. etc. v. CommissionerUnited States Tax Court · 1981
  5. Centex Corp. v. United StatesUnited States Court of Federal Claims · 2003

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