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1992 1,100,000 322,273
1992 1,250,000 382,177
1994 1,000,000 291,695
Petitioner Jacob Pinson made the following income
tax payments to the State of Israel during the taxable
years 1991, 1992 and 1994:
Year Flocktex Payment Israeli Income Tax Paid
1991 $875,000 $296,554
1992 1,100,000 322,273
1992 1,250,000 382,177
1994 1,000,000 291,695
Petitioner Rachel Sandman made the following
income tax payments to the State of Israel during the
taxable years 1991, 1992 and 1994:
Year Flocktex Payment Israeli Income Tax Paid
1991 $875,000 $296,554
1992 1,100,000 322,273
1992 1,250,000 382,177
1994 1,000,000 291,695
Based on the foregoing stipulations, we hold that
petitioners’ respective payments of Israeli income taxes are
deemed to satisfy the creditability requirements of section 901
and the regulations thereunder and to constitute foreign income
taxes within the meaning of section 164(a)(3). Consequently, a
deduction for these remittances may be included in the parties’
Rule 155 computations.
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