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BANK OF AMERICA NATIONAL T. & S. ASS'N v. UNITED STATES

Nos. 184-68, 138-69.

459 F.2d 513 (1972)

BANK OF AMERICA NATIONAL TRUST AND SAVINGS ASSOCIATION, a National Banking Association v. The UNITED STATES.

United States Court of Claims.

May 12, 1972.

Attorney(s) appearing for the Case

Harry R. Horrow, San Francisco, Cal., Attorney of Record, for plaintiff; Stephen J. Martin, David L. Klott, and Pillsbury, Madison & Sutro, San Francisco, Cal., of counsel.

Michael H. Singer, Washington, D. C., with whom was Asst. Atty. Gen. Scott P. Crampton, for defendant; Philip R. Miller, Washington, D. C., of counsel.

Before COWEN, Chief Judge, and DAVIS, SKELTON, NICHOLS, KASHIWA, and KUNZIG, Judges.

OPINION

DAVIS, Judge.*

For a domestic corporation, § 901(a) and (b) (1) of the Internal Revenue Code of 1954 allows a credit against federal income taxes of "the amount of any income, war profits and excess profits taxes paid or accrued during the taxable year to any foreign country or to any possession of the United States * * *."1 Bank of America National Trust and Savings Association, organized...

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