Legal Opinion
Third Scottish American Trust Co. v. United States
United States Court of Claims
Decided March 3, 1941No. 44071PublishedCited by 5 opinions
1Opinion of the Court
WHITAKER, Judge.
I. The plaintiff is a foreign corporation chartered under the laws of Great Britain. During the year 1933 it derived income from sources within the United States eon, sisting of interest and dividends. It seeks to deduct from such gross income a “ratable part” of its home office expenses, interest and British income taxes. The first question presented is the proper method of determining this “ratable part.”
The plaintiff says that this ratable part is the ratio between all of its gross income in the United States, including dividends, and its total gross income from all…
2Cases cited3 opinions
- Commissioner of Internal Revenue v. OPP Holding Corp.Court of Appeals for the Second Circuit · 1935
- Helvering v. Richmond, F. & P. R. Co.Court of Appeals for the Fourth Circuit · 1937
- London & Lancashire Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1936
3Cited by5 opinions
- Duluth-Superior Dredging Co. v. Commissioner of TaxationSupreme Court of Minnesota · 1944
- Commercial Union Assur. Co. v. CommissionerCourt of Appeals for the Second Circuit · 1944
- Jordan Co. v. AllenDistrict Court, M.D. Georgia · 1949
- Abad v. United StatesUnited States Court of Claims · 1956
- Union Assurance Society, Ltd. v. United StatesUnited States Court of Claims · 1943