The Commissioner determined deficiencies of $58,989.50 in income tax for 1937 and $231,529.47 in income tax and $20,607.92 in excess profits tax for 1938.
The principal issue is with regard to the credit for foreign taxes under section 131 of the Revenue Acts of 1936 and 1938. This includes (1) the determination of the meaning in subsection (b) of the term "net income," (2) whether royalties paid to domestic corporations in 1937, and excess profits taxes for 1938...
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