Bank of Am. Trust & Sav. Ass'n v. Commissioner
United States Tax Court
Petitioner claimed a credit against its income taxes under sec. 901, I.R.C. 1954, for certain Thailand, Philippines, Republic of China (Taiwan), and City of Buenos Aires taxes imposed in respect of the banking activities of its branches.
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Petitioner claimed a credit against its income taxes under sec. 901, I.R.C. 1954, for certain Thailand, Philippines, Republic of China (Taiwan), and City of Buenos Aires taxes imposed in respect of the banking activities of its branches. Held, since such taxes were imposed on gross income without deduction for any related costs and expenses, they did not constitute "income * * * taxes" within the meaning of sec. 901(b)(1). Bank of America National T. & S. Assn. v. United States, 459 F.2d 513 (Ct. Cl. 1972), followed.
1Opinion of the Court
Bank of America National Trust and Savings Association, a National Banking Association, Petitioner v. Commissioner of Internal Revenue, Respondent
Bank of Am. Trust & Sav. Ass'n v. Commissioner
Docket No. 3568-71
United States Tax Court
61 T.C. 752; 1974 U.S. Tax Ct. LEXIS 138; 61 T.C. No. 81;
March 18, 1974, Filed
Decision will be entered under Rule 155.
Petitioner claimed a credit against its income taxes under sec. 901, I.R.C. 1954, for certain Thailand, Philippines, Republic of China (Taiwan), and City of Buenos Aires taxes imposed in respect of the banking activities of its branches. Held,…
2Cases cited18 opinions
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
- Jarecki v. G. D. Searle & Co.Supreme Court of the United States · 1961
- Reese v. CommissionerUnited States Tax Court · 1966
- United States v. Rhode Island Hospital Trust CompanyCourt of Appeals for the First Circuit · 1966
- Penn Mut. Indem. Co. v. CommissionerUnited States Tax Court · 1959
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