Legal Opinion
Norwest Corp. v. Commissioner
Court of Appeals for the Eighth Circuit
Decided November 14, 1995No. Nos. 93-1274, 93-1741PublishedCited by 14 opinions
1Opinion of the Court
McMILLIAN, Circuit Judge.
Norwest Corporation and Affiliated Companies (Norwest) appeal from a final order entered in the United States Tax Court1 assessing and ordering Norwest to pay income tax deficiencies for its 1980 and 1982 taxable years. Norwest Corp. v. Commissioner, 63 T.C.M. (CCH) 3023, 1992 WL 103666 (1992). For reversal, Norwest claims that the tax court improperly held that it was not entitled to foreign tax credits (FTCs) under 26 U.S.C. § 901 for income taxes paid to the Brazilian government pursuant to Brazil’s tax on interest income earned by foreign lenders. Norwest claims…
2Cases cited19 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Ford Motor Credit Co. v. MilhollinSupreme Court of the United States · 1980
- Bingler v. JohnsonSupreme Court of the United States · 1969
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
14 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Bankers Trust New York Corporation and Consolidated Subsidiaries v. United StatesCourt of Appeals for the Federal Circuit · 2000
- United States v. Jim Guy TuckerCourt of Appeals for the Eighth Circuit · 2000
- Amoco Corporation (Formerly Standard Oil Company (Indiana)) and Affiliated Corporations v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1998
- All American Telephone Co. v. Federal Communications CommissionCourt of Appeals for the D.C. Circuit · 2017
- Riggs Nat'l Corp. & Subsidiaries v. CommissionerUnited States Tax Court · 1996
9 more not listed; retrieve them via the Exa API.