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
OPINION.
Opper, Judge:
A deficiency in the amount of $2,069.18 in income tax for the year 1939 is contested by petitioner. The question raised is the correct amount of the deduction on account of home office expense and British income tax which may be taken by petitioner, a foreign insurance company, other than life or mutual, doing business in the United States.
The facts are all established by a stipulation, the principal part of which reads as follows:
I
The jjetitioner is a foreign corporation, organized and existing under the laws of Great Britain. During the year 1939 it was engaged in the…
2Cases cited1 opinion
- Commercial Union Assurance Co. v. CommissionerUnited States Tax Court · 1943
3Cited by1 opinion
- Palatine Ins. Co. v. CommissionerUnited States Tax Court · 1944