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THIRD SCOTTISH AMERICAN TRUST CO. v. UNITED STATES

No. 44071.

37 F.Supp. 279 (1941)

THIRD SCOTTISH AMERICAN TRUST CO., Ltd., v. UNITED STATES.

Court of Claims.

March 3, 1941.

Attorney(s) appearing for the Case

Ralph P. Wanlass, of Washington, D. C. (Walter G. Moyle and Earl B. Breeding, both of Washington, D. C., on the brief), for plaintiff.

J. W. Hussey, of Washington, D. C., and Samuel O. Clark, Jr., Asst. Atty. Gen. (Robert N. Anderson and Fred K. Dyar, both of Washington, D.C., on the brief), for defendant.

Before WHALEY, Chief Justice, LITTLETON, WHITAKER, JONES, and MADDEN, Judges.

WHITAKER, Judge.

I. The plaintiff is a foreign corporation chartered under the laws of Great Britain. During the year 1933 it derived income from sources within the United States consisting of interest and dividends. It seeks to deduct from such gross income a "ratable part" of its home office expenses, interest and British income taxes. The first question presented is the proper method of determining this "ratable part...

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