Legal Opinion

International Tel. & Tel. Corp. etc. v. Commissioner

United States Tax Court

Decided July 9, 1981No. Docket No. 7990-75Published

Petitioners are an affiliated group of corporations which filed a consolidated return in 1965. A. Foreign Tax Credit Issues 1. Held, members of the group which had foreign source gross income but incurred foreign source operating losses must be included in calculating petitioners' consolidated foreign source taxable income for purposes of the foreign tax credit limitation. 2. Held, deductions resulting from service fee and interest payments by members of the group to other…

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Petitioners are an affiliated group of corporations which filed a consolidated return in 1965. A. Foreign Tax Credit Issues 1. Held, members of the group which had foreign source gross income but incurred foreign source operating losses must be included in calculating petitioners' consolidated foreign source taxable income for purposes of the foreign tax credit limitation. 2. Held, deductions resulting from service fee and interest payments by members of the group to other members should be apportioned to foreign source gross income in determining the consolidated foreign source taxable…

1Opinion of the Court

* International Telephone & Telegraph Corporation and Affiliated Companies, Petitioners v. Commissioner of Internal Revenue, Respondent

International Tel. & Tel. Corp. etc. v. Commissioner

Docket No. 7990-75

United States Tax Court

77 T.C. 60; 1981 U.S. Tax Ct. LEXIS 100;

July 9, 1981, Filed

Decision will be entered under Rule 155.

Petitioners are an affiliated group of corporations which filed a consolidated return in 1965.

A. Foreign Tax Credit Issues

1. Held, members of the group which had foreign source gross income but incurred foreign source operating losses must be included in calculating…

2Cases cited38 opinions

  1. Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
  2. Hanover Bank v. CommissionerSupreme Court of the United States · 1962
  3. Commissioner v. GordonSupreme Court of the United States · 1968
  4. J. E. Davant and Kathryn Davant v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. J. E. Davant and Kathryn DavantCourt of Appeals for the Fifth Circuit · 1966
  5. South Texas Rice Warehouse Co. v. CommissionerUnited States Tax Court · 1965

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