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THEO. H. DAVIES & CO. v. COMMISSIONER

Docket No. 8491-78.

75 T.C. 443 (1980)

THEO. H. DAVIES & CO., LTD. & SUBSIDIARIES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 29, 1980.

Attorney(s) appearing for the Case

Richard L. Griffith, John E. McDermott, and Guy P. Novo, for the petitioners.

Theodore J. Kletnick and David M. Brandes, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined deficiencies in petitioners' income tax of $73,594 and $417,983 for the taxable years ending December 31, 1972, and December 31, 1973, respectively. The sole issue to be decided is the proper treatment of capital losses incurred outside the United States in computing the overall foreign tax credit pursuant to section 904(a)(2).1

This case was submitted fully stipulated...

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