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INTERNATIONAL TELEPHONE & TELEGRAPH CORP. v. COMMISSIONER

Docket No. 7990-75.

77 T.C. 60 (1981)

INTERNATIONAL TELEPHONE & TELEGRAPH CORPORATION AND AFFILIATED COMPANIES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 9, 1981.

Attorney(s) appearing for the Case

Stephen D. Gardner, Abraham N. M. Shashy, Jr., and Robert A. Kagan, for the petitioners.

Joan Ronder Domike, for the respondent.

OPINION

TANNENWALD, Chief Judge:

Respondent determined a deficiency in petitioners' income tax for 1965 of $885,064. Concessions have been made by both parties, but several issues remain. The first two, relating to the limitation on the foreign tax credit, are:

(1) Whether the foreign source operating losses of certain foreign corporations, affiliated with International Telephone & Telegraph Corp...

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