- 2 -
I.R.C., and the regulations thereunder, including
Example (3) of sec. 1.901-2(f)(2)(ii), Income Tax Regs.
Held, further, there was no indirect subsidy to P with
respect to E's credit practice. Held, further, the
requirements of foreign tax creditability under secs.
901-908, I.R.C., have been satisfied with respect to
Egyptian income taxes paid on behalf of S by E.
Robert L. Moore, II, Jay L. Carlson, Emmett B. Lewis, J.
Bradford Anwyll, Kevin L. Kenworthy, Laura G. Ferguson, and James
J. Lenahan, for petitioner.
William G. Merkle, Cynthia J. Mattson, William B. Lowrance,
Paul S. Manning, Michael J. Calabrese, Jan E. Lamartine, Bettie
N. Ricca, and Joan M. Thomsen, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
TANNENWALD, Judge: Respondent determined deficiencies in
petitioner's 1980, 1981, and 1982 Federal income taxes in the
amounts of $109,618,203, $200,848,534, and $155,776,311,
respectively. The issue for decision is whether petitioner is
entitled, under section 901,1 to foreign tax credits for Egyptian
income taxes purportedly paid or accrued for the years 1979-
1982.2
1 All statutory references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
2 In the petition, petitioner affirmatively claimed additional
depletion deductions in the amounts of $738,084, $1,069,353, and
$1,273,498, for 1980, 1981, and 1982, respectively, as well as
reductions of petitioner's dividend income for 1980 and 1982 in
(continued...)
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