AMF INC. v. UNITED STATES

No. 7-75.

610 F.2d 739 (1979)

AMF INCORPORATED v. The UNITED STATES.

United States Court of Claims.

November 14, 1979.


Attorney(s) appearing for the Case

Eric R. Fox, Washington, D. C., attorney of record, for plaintiff; Ivins, Phillips & Barker, Washington, D. C., of counsel.

Bruce W. Reynolds, Washington, D. C., with whom was Asst. Atty. Gen. M. Carr Ferguson, Washington, D. C., for defendant; Theodore D. Peyser, Jr., and Donald H. Olson, Washington, D. C., of counsel.

Before KASHIWA, KUNZIG and BENNETT, Judges.


OPINION

KASHIWA, Judge:

This income tax case comes before the court on the parties' stipulation of facts. Plaintiff, AMF Incorporated (AMF), seeks a refund for taxes and interest paid for its 1965 and 1966 tax years. At issue is the interpretation of the regulations promulgated under I.R.C. § 963. We must decide whether plaintiff was correct in applying the special rules of Treas.Reg. § 1.963-4 in determining the amount of its foreign tax credit...

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