The Commissioner issued a notice of deficiency advising petitioner of the determination of a deficiency in income tax for the year 1935 in the sum of $12,686.02 and of an overassessment in excess profits tax for the same year in the sum of $2,030.23. The only issue is whether the withholding of certain amounts at the source from royalties paid to petitioner entitle it to a credit under section 131 (a) (1) of the Revenue Act of 1934 for income taxes paid or accrued to a foreign...
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