Legal Opinion
New York & H. Rosario Min. Co. v. Commissioner of Int. Rev.
Court of Appeals for the Second Circuit
Decided June 1, 1948No. 250, Docket 20894PublishedCited by 18 opinions
1Opinion of the Court
SWAN, Circuit Judge.
The petitioner is a New York corporation engaged in gold and silver mining operations in the Republic of Honduras. During the taxable years in suit it paid taxes to the Honduras Government which it contends were “income taxes” entitling it to credits against its United States income taxes for the same years by virtue of section 131(a) (1) of the Internal Revenue Code, printed in the margin. The Tax Court’s disallowance of the credits, 8 T.C. 1232, resulted in the deficiencies before us for review.
Mining operations in Honduras are regulated by a comprehensive mining Code,…
2Cases cited7 opinions
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- Biddle v. CommissionerSupreme Court of the United States · 1938
- Burnet v. Chicago Portrait Co.Supreme Court of the United States · 1932
- Keasbey & Mattison Co. v. RothensiesCourt of Appeals for the Third Circuit · 1943
- New York & Honduras Rosario Mining Co. v. CommissionerUnited States Tax Court · 1947
2 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Commissioner of Internal Revenue v. The American Metal Co., Limited, the American Metal Co., Limited v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1955
- Missouri Pacific Railroad Company v. The United StatesUnited States Court of Claims · 1968
- Northwestern Mut. Fire Ass'n v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1950
- Bank of America National Trust & Savings Ass'n v. United StatesUnited States Court of Claims · 1972
- Phillips Petroleum Co. v. CommissionerUnited States Tax Court · 1995
13 more not listed; retrieve them via the Exa API.