Eastman Kodak Co. v. United States

WHITAKER, Judge.

This case involves the question of the credit to which a taxpayer is entitled for foreign taxes paid by its foreign subsidiary.

Until 1931 a taxpayer had been permitted to take credit for foreign taxes paid computed according to the formula insisted upon by plaintiff, but in that year the Commissioner changed the formula to that applied in this case. The same question was presented in American Chicle Company v. United States, 94 Ct.Cl. 699; 316 U.S. 450, 62 S.Ct. 1144, 86 L.Ed. 1591, except that the years involved in that case were after the change in practice, and the years…