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PINSON v. COMMISSIONER

Docket Nos. 7561-98, 7562-98, 7563-98, 7564-98, 7565-98, 7566-98, 7567-98, 19353-98, 19354-98, 19355-98, 19356-98, 19357-98, 19358-98, 19359-98.

80 T.C.M. 939 (2000)

T.C. Memo. 2000-393

Jacob and Chana Pinson, et al v. Commissioner.

United States Tax Court.

Filed December 28, 2000.

Attorney(s) appearing for the Case

Robert J. Percy, Bruce I. Judelson, Richard A. Levine,2 Mortimer M. Caplin,3 Richard E. Timbie, and Christopher S. Rizek, for the petitioners. Stephen C. Best and Bradford A. Johnson, for the respondent.

SUPPLEMENTAL MEMORANDUM OPINION

NIMS, Judge:

On July 6, 2000, the Court filed its opinion in this case, T.C. Memo. 2000-208, in which we disallowed petitioners' claimed foreign tax credits. We further held that petitioners could not reserve the right, as part of a Rule 155 computation, to elect to take deductions for foreign taxes in lieu of the disallowed foreign tax credits. This issue, raised for the first time on...

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