Jacob and Chana Pinson, et al. - Page 9




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          later contended as an alternative argument that petitioners had             
          failed to show that the Israeli tax payments satisfied the                  
          creditability requirements of section 901 and the regulations               
          thereunder.  We did not reach this argument in our previous                 
          opinion as it was mooted by our decision relating to the source             
          of petitioners’ income.                                                     
               Here then is the situation with which we are now faced.  A             
          plain reading of the parties’ stipulations would seem to indicate           
          that respondent did not reserve the right to question the nature            
          of the remittances to Israel when he stipulated that they were              
          “Israeli Income Tax Paid”.  Such, in turn, appears to have lulled           
          petitioners into assuming that respondent had conceded the                  
          payments to be foreign income taxes as required for either a                
          credit or the alternative deduction.  Consequently, petitioners             
          further assumed, the factual predicate having been established,             
          that the deductions fell within the standard for items which may            
          be taken into account under Rule 155.                                       
               Under Rule 155, the parties “submit computations pursuant to           
          the Court’s determination of the issues”.  Rule 155(a).  Thus the           
          Rule constitutes “the mechanism whereby the Court is enabled to             
          enter a decision for the dollar amounts of deficiencies and/or              
          overpayments” resulting from the Court’s substantive disposition.           
          Cloes v. Commissioner, 79 T.C. 933, 935 (1982).  A Rule 155                 
          proceeding is an appropriate vehicle for dealing with “‘purely              






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