Legal Opinion
American Telephone & Telegraph Co. v. United States
District Court, S.D. New York
Decided April 15, 1977No. 76 Civ. 571PublishedCited by 2 opinions
1Opinion of the Court
OPINION
ROBERT L. CARTER, District Judge.
Plaintiff (“ATT”) and defendant both move pursuant to Rule 56(a), F.R.Civ.P., for summary judgment. They have submitted a joint 9(g) statement, and there are no material issues of fact to be resolved.
Facts 1
When ATT filed its 1964 federal income tax return, it claimed a foreign tax credit of $269,085.10 based on its payment of a 15% Canadian income tax of non-residents for 1964. 2 In 1966 Canada made an additional assessment of $763,272.90 Canadian dollars against ATT for 1964 under the same 15% Canadian income tax of non-residents. 3 Although…
2Cases cited3 opinions
- Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
- Bank of America National Trust & Savings Ass'n v. United StatesUnited States Court of Claims · 1972
- Comprehensive Designers International, Ltd. v. CommissionerUnited States Tax Court · 1976
3Cited by2 opinions
- American Telephone & Telegraph Co. v. United StatesCourt of Appeals for the Second Circuit · 1978
- American Telephone and Telegraph Co. v. United StatesCourt of Appeals for the Second Circuit · 1978