Palatine Ins. Co. v. Commissioner
United States Tax Court
Deduction for British income taxes paid by petitioner, a foreign insurance corporation doing business in the United States, held, allowable to the extent of a "ratable" portion of the tax computed by comparing petitioner's gross income from taxable sources within the United States with total gross income, and without further limitation.
1Opinion of the Court
Palatine Insurance Company, Limited, Petitioner, v. Commissioner of Internal Revenue, Respondent
Palatine Ins. Co. v. Commissioner
Docket No. 2446
United States Tax Court
4 T.C. 239; 1944 U.S. Tax Ct. LEXIS 35;
October 23, 1944, Promulgated
Decision will be entered under Rule 50.
Deduction for British income taxes paid by petitioner, a foreign insurance corporation doing business in the United States, held, allowable to the extent of a "ratable" portion of the tax computed by comparing petitioner's gross income from taxable sources within the United States with total gross income, and without…
2Cases cited2 opinions
- Commercial Union Assurance Co. v. CommissionerUnited States Tax Court · 1943
- Palatine Ins. Co. v. CommissionerUnited States Tax Court · 1944