- 56 - corporate income tax returns on behalf of itself and its domestic subsidiaries for the taxable years ended December 31, 1979, December 31, 1980, December 31, 1981, and December 31, 1982, with the District Director, Chicago, Illinois, reflecting Amoco's timely election to: (1) Apply the provisions of the 1983 foreign tax credit regulations retroactively to the years at issue, and (2) apply the "safe harbor" method of determining allowable foreign tax credits with respect to Egyptian taxes. Applying the "safe harbor" method in its amended returns, petitioner treated portions of the Egyptian income taxes reported on its original returns as creditable taxes. The remainder was deducted in computing taxable income. The amounts reported on petitioner's amended returns are summarized as follows: Year Credit Claimed Deducted Total 1979 $215,414,631 $ 88,601,262 $304,015,893 1980 459,881,927 38,204,353 498,086,280 1981 383,993,639 173,879,789 557,873,428 1982 308,490,746 145,095,933 453,586,679 Egyptian income taxes claimed as foreign tax credits by Amoco in 1979 were not utilized to reduce Amoco's 1979 U.S. tax liability and were carried forward to 1980 and subsequent tax years. On June 18, 1992, respondent issued a statutory notice of deficiency to petitioner for the 1980, 1981, and 1982 tax years. In the notice of deficiency, respondent determined that Amoco Egypt's Egyptian income taxes had not been paid within thePage: Previous 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 Next
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