Renee Vento v. Commissioner

152 T.C. No. 1

UNITED STATES TAX COURT RENEE VENTO, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket Nos. 992-06, 993-06, Filed February 4, 2019. 1168-06. Following our previous Opinion holding that Ps are not entitled to foreign tax credits under I.R.C. sec. 901 for certain amounts paid to the U.S. Virgin Islands, the parties were ordered to submit computa- tions for entry of decision under Tax Court Rule 155. In their compu- tations Ps took the position that the amounts at issue were deductible as State or local taxes under I.R.C. sec. 164(a)(3), an argument they…