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CHAMPION INTERNATIONAL CORP. v. COMMISSIONER

Docket No. 2585-79.

81 T.C. 424 (1983)

CHAMPION INTERNATIONAL CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 20, 1983.

Attorney(s) appearing for the Case

J. Phillip Adams, Jay David Gayner, and James A. Levitan, for the petitioner.

W. Edward Williams and Robert J. Percy, for the respondent.

OPINION

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $1,149,015 in petitioner's Federal income tax for 1972. The only issue remaining for decision is the amount of Canadian taxes paid by petitioner's Canadian subsidiary which will be deemed to have been paid by petitioner pursuant to section 902(a)1 as a result of a dividend it received from the subsidiary...

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