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FEDERATED MUTUAL IMPLEMENT & HARD. INS. CO. v. C. I. R.

No. 16057.

266 F.2d 66 (1959)

FEDERATED MUTUAL IMPLEMENT & HARDWARE INSURANCE CO., a corporation, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Eighth Circuit.

May 4, 1959.

Attorney(s) appearing for the Case

Nicholas S. Kiefer, Chicago, Ill. (Hayner N. Larson, Minneapolis, Minn., was with him on the brief), for petitioner.

George F. Lynch, Attorney, Department of Justice, Washington, D. C. (Charles K. Rice, Asst. Atty. Gen., and Lee A. Jackson, and A. F. Prescott, Attorneys, Department of Justice, Washington, D. C., were with him on the brief), for respondent.

Before GARDNER, Chief Judge, and VOGEL and MATTHES, Circuit Judges.

MATTHES, Circuit Judge.

This case is here on petition to review decision of the Tax Court reported in 29 T.C. 262. This court has jurisdiction under Sections 7482(a) and 7483 of the Internal Revenue Code of 1954, 26 U.S. C.A. §§ 7482(a), 7483.

Broadly stated, the controversy is focused upon the amount of foreign tax credit to which the petitioner is entitled for the years 1948 to 1953 inclusive.

Mutual insurance...

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