Mid-Continent Supply Co. v. Commissioner
United States Tax Court
Held, for purposes of the overall limitation on foreign tax credit, the phrase "portion of the consolidated taxable income attributable to such [Western Hemisphere trade] corporations" in sec. 1503(b)(1), I.R.C. 1954, has the same meaning as it does in sec. 1.1502-25, Income Tax Regs., relating to the computation of the consolidated deduction under sec. 922, I.R.C. 1954. Held, further, this Court did not abuse its discretion in denying a motion for continuance, filed by…
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Held, for purposes of the overall limitation on foreign tax credit, the phrase "portion of the consolidated taxable income attributable to such [Western Hemisphere trade] corporations" in sec. 1503(b)(1), I.R.C. 1954, has the same meaning as it does in sec. 1.1502-25, Income Tax Regs., relating to the computation of the consolidated deduction under sec. 922, I.R.C. 1954. Held, further, this Court did not abuse its discretion in denying a motion for continuance, filed by petitioner to obtain time to seek through discovery a technical advice memorandum, and facts relating thereto, allegedly…
1Opinion of the Court
OPINION
Featherston, Judge:
Respondent determined deficiencies in the amounts of $532,874.53 and $126,178.29 in petitioner’s Federal income tax for 1969 and 1970, respectively. Petitioner did not contest the determination of the deficiency for 1969; other issues having been settled by the parties, the issues remaining for decision as to the 1970 taxable year are as follows:(1) Whether the foreign tax credit allowable in respect of Western Hemisphere trade corporation members of an affiliated group of petitioner’s corporations filing a consolidated Federal income tax return for 1970 should be…
2Cases cited6 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Dixon v. United StatesSupreme Court of the United States · 1965
- Karl F. Knetsch and Eva Fay Knetsch v. The United StatesUnited States Court of Claims · 1965
- Edwin O. Bookwalter v. Joseph H. And Frances R. BreckleinCourt of Appeals for the Eighth Circuit · 1966
- Teichgraeber v. CommissionerUnited States Tax Court · 1975
1 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Rowlee v. CommissionerUnited States Tax Court · 1983
- Jaggard v. CommissionerUnited States Tax Court · 1981
- Union Carbide Corp. v. CommissionerUnited States Tax Court · 1980
- Union Carbide Corp. v. United StatesUnited States Court of Claims · 1979
- Mid-Continent Supply Co. v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1978
9 more not listed; retrieve them via the Exa API.