Mid-Continent Supply Co. v. Commissioner of Internal Revenue Service

RONEY, Circuit Judge:

This is an appeal from a decision of the United States Tax Court determining a deficiency in federal income taxes for the taxable year 1970 in the amount of $126,-178.29. The opinion of the Tax Court is reported at 67 T.C. 37. Although we are satisfied with the reasons for decision in that opinion, it seems appropriate to set forth the facts and the holding here so that our decision will furnish a clear precedent in this Circuit on this technical point of tax law.

We hold that in determining the amount of foreign tax credit allowable to Western Hemisphere trade…