Gleason Works v. Commissioner
United States Tax Court
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…
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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
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- New York Trust Co. v. EisnerSupreme Court of the United States · 1921
- United States v. Skelly Oil Co.Supreme Court of the United States · 1969
- Biddle v. CommissionerSupreme Court of the United States · 1938
- United States v. New YorkSupreme Court of the United States · 1942
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