RAUM, Judge:
The Commissioner determined a deficiency in petitioner's Federal corporate income tax for the calendar year 1969 in the amount of $143,085.07. The sole issue raised by the petition is whether petitioner is entitled, pursuant to section 901(a), I.R.C. 1954, to a credit of $224,074 for amounts withheld and paid to Switzerland by petitioner's Swiss subsidiary as a withholding tax on amounts repatriated to petitioner pursuant to Rev. Proc. 65-17, 1965...
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