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UNITED STATES v. GOODYEAR TIRE & RUBBER CO.

No. 88-1474.

493 U.S. 132 (1989)

UNITED STATES v. GOODYEAR TIRE & RUBBER CO. ET AL.

Supreme Court of United States.

Decided December 11, 1989

Attorney(s) appearing for the Case

Alan I. Horowitz argued the cause for the United States. With him on the briefs were Solicitor General Starr, Assistant Attorney General Peterson, Deputy Solicitor General Wallace, and Robert S. Pomerance.

Barring Coughlin argued the cause for respondents. With him on the brief were Stephen L. Buescher and Deborah Z. Read.*

JUSTICE MARSHALL delivered the opinion of the Court.

In this case, we must decide whether "accumulated profits" in the indirect tax credit provision of the Internal Revenue Code of 1954, 26 U. S. C. § 902 (1970 ed.), are to be measured in accordance with United States or foreign tax principles. We conclude that "accumulated profits" are to be measured in accordance with United States principles.

I

Goodyear Tyre and Rubber Company (Great Britain...

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