Memorandum Opinion
TRAIN, Judge:
The respondent determined a deficiency in income tax of the petitioner for the taxable year ended December 31, 1950, in the amount of $21,353.82. The petitioner claims an overpayment for the same year in the amount of $13,380.95.
The sole issue for decision concerns the proper method of computing the foreign tax credit under section 131 of the Internal Revenue Code of 1939.
Petitioner filed its 1950 income...
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