Motors Insurance v. United States

This income tax refund litigation comes before ns upon a stipulation of facts pursuant to Rule 134(b) of the Rules of this court. Because of similarity of issues, the cases are consolidated for decision. We are invited in each Case to decide issues involving the foreign tax credit, which the. parties represent to be questions of first impression. First, *574where a corporate taxpayer seeks a net operating loss carry-back adjustment for a prior taxable year in which it claimed and was allowed a foreign tax credit, we are asked whether the prior year’s foreign tax credit limitation imposed by…