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GRUNEBAUM v. COMMISSIONER

Docket Nos. 4170-66, 4171-66.

50 T.C. 710 (1968)

ERICH O. AND GABRIELE H. GRUNEBAUM, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. KURT H. AND ANNELIESE GRUNEBAUM, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 6, 1968.

Attorney(s) appearing for the Case

Michael I. Smith, for the petitioners.

Bernard Goldstein and Robert S. Gorin, for the respondent.

The Commissioner determined deficiencies in the income tax of petitioners Erich and Gabriele Grunebaum and petitioners Kurt and Anneliese Grunebaum for the year 1961 in the amounts of $37,490.69 and $39,435.07, respectively. As a result of concessions made by the petitioners approximately three-fourths of these deficiencies are no longer being contested. The remaining matter in the dispute relates to the application of the overall limitation on the credit for foreign taxes...

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