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GLEASON WORKS v. COMMISSIONER

Docket No. 2651-70.

58 T.C. 464 (1972)

GLEASON WORKS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 15, 1972.

Attorney(s) appearing for the Case

Richard S. Fischer, for the petitioner.

Stephen M. Miller, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined a deficiency in petitioner's income tax in the amount of $46,763.71 for the taxable year 1965. The sole issue for decision is whether petitioner is entitled to a foreign tax credit under section 9011 for the amount of British income tax on interest due from its wholly owned subsidiary and in respect of which tax was paid by the subsidiary and withheld by the subsidiary from...

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