Zuanich v. Commissioner
United States Tax Court
Petitioner-husband discussed with respondent's agents the availability of the foreign tax credit on account of Canadian taxes paid by a corporation of which petitioner-husband was majority shareholder. Held, the doctrine of equitable estoppel does not bar respondent from disallowing this credit ( Automobile Club of Michigan v. Commissioner, 353 U.S. 180 (1957)); this credit is not allowable.
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Petitioner-husband discussed with respondent's agents the availability of the foreign tax credit on account of Canadian taxes paid by a corporation of which petitioner-husband was majority shareholder. Held, the doctrine of equitable estoppel does not bar respondent from disallowing this credit ( Automobile Club of Michigan v. Commissioner, 353 U.S. 180 (1957)); this credit is not allowable. Petitioner-husband purchased and placed into service on his commercial fishing vessel a hydraulic fishing reel. He purchased the reel entirely with funds withdrawn from a capital construction fund…
1Concurring in part, dissenting in partGoffe, J.
I fully concur with the majority as to the foreign tax credit issue but respectfully dissent as to the investment credit issue. I would, instead, reach the result reached by the Court of Claims in the following eight cases: Pacific Far East Line, Inc. v. United States, 211 Ct. Cl. 71, 544 F.2d 478 (1976); Pacific Transport Co. v. United States, 211 Ct. Cl. 99, 544 F.2d 493 (1976); Delta Steamship Lines, Inc. v. United States, 211 Ct. Cl. 104, 544 F.2d 496 (1976); Oglebay Norton Co. v. United States, 221 Ct. Cl. 749, 610 F.2d 715 (1979); O. L. Schmidt Barge Lines, Inc. v. United States, 221…
2Cases cited14 opinions
- Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
- United Telecommunications, Inc. (Formerly United Utilities, Incorporated) v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1978
- Minot Federal Savings & Loan Assn. v. United StatesCourt of Appeals for the Eighth Circuit · 1970
- Rockford Life Insurance v. CommissionerSupreme Court of the United States · 1934
- United Telecommunications, Inc. v. CommissionerUnited States Tax Court · 1975
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