Gulf-Puerto Rico Lines, Inc. v. Commissioner
United States Tax Court
Petitioner, a foreign corporation, paid taxes to the Commonwealth of Puerto Rico on gross income from all sources whatever. Under sec. 882 its United States source income was taxable in the United States and it was entitled to deductions connected with that United States income including foreign taxes paid with respect thereto. Under Puerto Rico law it was also entitled to a credit against that jurisdiction's taxes for United States taxes paid.
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Petitioner, a foreign corporation, paid taxes to the Commonwealth of Puerto Rico on gross income from all sources whatever. Under sec. 882 its United States source income was taxable in the United States and it was entitled to deductions connected with that United States income including foreign taxes paid with respect thereto. Under Puerto Rico law it was also entitled to a credit against that jurisdiction's taxes for United States taxes paid. During the years in issue petitioner chose to deduct a portion of its Puerto Rico taxes against United States source income rather than increasing its…
1Opinion of the Court
OPINION
StekREtt, Judge:
The Commissioner determined deficiencies in the petitioner’s Federal income taxes as follows:
Year Deficiency Year Deficiency
1958 - $7,125.89 1961_$105,121.66
1959 - 125,658.60 1962 _ 61,544.72
1960 - 134,859.41 1963_ 12,154.04
Some of the issues have been settled, leaving the following issues for our consideration:(1) Whether the petitioner may deduct from its gross income from sources within the United States any portion, of income taxes paid with respect to said income to Puerto Rico for the years 1959 through 1963.(2) Whether petitioner is entitled to an offset or…
2Cases cited2 opinions
- Corporacion De Ventas De Salitre Y Yoda De Chile v. CommissionerCourt of Appeals for the Second Circuit · 1942
- Corporacion de Ventas de Salitre y Yoda v. CommissionerUnited States Board of Tax Appeals · 1941
3Cited by1 opinion
- Gulf-Puerto Rico Lines, Inc. v. CommissionerUnited States Tax Court · 1974