Amoco Corporation (Formerly Standard Oil Company (Indiana) and Affiliated Corporations - Page 57

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          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.                                                        




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