Legal Opinion

Palatine Ins. Co. v. Commissioner

United States Tax Court

Decided October 23, 1944No. Docket No. 2446Published

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

  1. Commercial Union Assurance Co. v. CommissionerUnited States Tax Court · 1943
  2. Palatine Ins. Co. v. CommissionerUnited States Tax Court · 1944

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