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CARBORUNDUM CO. v. COMMISSIONER

Docket No. 7779-70.

58 T.C. 909 (1972)

CARBORUNDUM COMPANY, A DELAWARE CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 28, 1972.

Attorney(s) appearing for the Case

Walter A. Slowinski and Dennis I. Meyer, for the petitioner.

Stephen M. Miller, for the respondent.

TANNENWALD, Judge:

Respondent determined deficiencies in petitioner's income tax for the taxable years 1961 and 1962 in the amounts of $65,272 and $354,020, respectively. The sole issue involved is the amount of the dividend that should be utilized as the numerator of the first fraction applicable in calculating the foreign tax credit to which petitioner is entitled under section 902(a).1

OPINION

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