COLVIN, Judge:
Respondent determined deficiencies in petitioner's Federal income tax of $563,127 for 1979, $10,998,770 for 1980, and $1,794,073 for 1981. The sole issue for decision is whether the Ontario Mining Tax (OMT) is creditable under section 901. We hold that it is.
Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure...
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