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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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