- 57 - meaning of section 901 and the regulations thereunder. Respondent disallowed all of petitioner's foreign tax credits relating to Egyptian income taxes for the 1980, 1981, and 1982 tax years, as well as the Egyptian foreign tax credit carryforward from 1979. Respondent also decreased petitioner's gross income by amounts corresponding to the foreign tax credits claimed for the 1980, 1981, and 1982 tax years. Petitioner timely filed a petition with this Court on September 11, 1992, contesting the proposed deficiencies in tax, and claiming an overpayment of tax plus interest in respect of other items.9 OPINION Section 901 allows a domestic corporation a credit against its Federal income tax in the amount of any taxes paid or accrued during the taxable years to any foreign country. See American Chicle Co. v. United States, 316 U.S. 450 (1942). The purpose of the credit is to reduce international double taxation. Id. at 452. Whether petitioner is entitled to foreign tax credits is to be determined by applying principles of domestic tax law. United States v. Goodyear Tire & Rubber Co., 493 U.S. 132 (1989); Phillips Petroleum Co. v. Commissioner, 104 T.C. 256, 295 (1995). In applying this mandate, however, we look first to the law of 9 See supra note 2.Page: Previous 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 Next
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