The Commissioner determined a deficiency of $2,180,517.99 in the income tax of the petitioner based upon a consolidated return for 1947. The petitioner raises but one issue for decision and that is whether mining production taxes imposed by the Republic of Mexico constitute income taxes or taxes in lieu of income taxes within the meaning of section 131 (a) (1) or (h) so as to entitle the petitioner to the credit provided in section 131 (f) (1). The only other issue for decision...
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