Legal Opinion

Gleason Works v. Commissioner

United States Tax Court

Decided June 15, 1972No. Docket No. 2651-70Published

Petitioner was owed $ 221,839.43 by its wholly owned British subsidiary. In 1965, the latter paid petitioner $ 135,876.73 and withheld the amount of British tax payable in the United Kingdom on income of $ 221,839.43, pursuant to sec. 169 of the British Income Tax Act of 1952, to wit, $ 85,962.70. On its return for 1965, petitioner reported as interest income the $ 135,876.73 which it received, added to this amount, i.e., "grossed up," the amount of British tax withheld by…

Read the full summary

Petitioner was owed $ 221,839.43 by its wholly owned British subsidiary. In 1965, the latter paid petitioner $ 135,876.73 and withheld the amount of British tax payable in the United Kingdom on income of $ 221,839.43, pursuant to sec. 169 of the British Income Tax Act of 1952, to wit, $ 85,962.70. On its return for 1965, petitioner reported as interest income the $ 135,876.73 which it received, added to this amount, i.e., "grossed up," the amount of British tax withheld by the payor, and claimed a foreign tax credit in the amount of $ 85,962.70 under sec. 901, I.R.C. 1954. Held, the British…

1Opinion of the Court

Gleason Works, Petitioner v. Commissioner of Internal Revenue, Respondent

Gleason Works v. Commissioner

Docket No. 2651-70

United States Tax Court

58 T.C. 464; 1972 U.S. Tax Ct. LEXIS 105;

June 15, 1972, Filed

Decision will be entered for the petitioner.

Petitioner was owed $ 221,839.43 by its wholly owned British subsidiary. In 1965, the latter paid petitioner $ 135,876.73 and withheld the amount of British tax payable in the United Kingdom on income of $ 221,839.43, pursuant to sec. 169 of the British Income Tax Act of 1952, to wit, $ 85,962.70. On its return for 1965, petitioner reported as…

2Cases cited20 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. New York Trust Co. v. EisnerSupreme Court of the United States · 1921
  3. United States v. Skelly Oil Co.Supreme Court of the United States · 1969
  4. Biddle v. CommissionerSupreme Court of the United States · 1938
  5. United States v. New YorkSupreme Court of the United States · 1942

15 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API