Commercial Union Assur. Co. v. Commissioner

CHASE, Circuit Judge.

Upon the taxpayer’s previous petitions to review decisions of the Tax Court, 1 T.C. 1166, redetermining deficiencies in its income taxes for 1938 and 1939, we modified the decisions and held that the taxpayer was entitled to take credit for British taxes paid by it upon the net income of its American subsidiaries to the extent that those taxes were connected with so much of its income from sources within the United States as is not made tax-free by the credit provided in § 204(a) (2) (B) of the Revenue Act of 1938, 26 U.S.C.A. Int.Rev.Acts, page 1090, and were “not in…