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BLACK & DECKER CORP. v. C.I.R.

No. 92-1188.

986 F.2d 60 (1993)

The BLACK & DECKER CORPORATION, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided February 3, 1993.

Attorney(s) appearing for the Case

Herbert Odell, Zapruder & Odell, Berwyn, PA, argued (Joel C. Weiss, Zapruder & Odell, Berwyn, PA, on brief), for petitioner-appellant.

Frank Phillip Cihlar, Tax Div., U.S. Dept. of Justice, Washington, DC (James A. Bruton, Acting Asst. Atty. Gen., Gary R. Allen, Gilbert S. Rothenberg, Tax Div. U.S. Dept. of Justice, Washington, DC, on brief), for respondent-appellee.

Before ERVIN, Chief Judge, LUTTIG, Circuit Judge, and TRAXLER, United States District Judge for the District of South Carolina, sitting by designation.

OPINION

ERVIN, Chief Judge:

The Black & Decker Corporation, a domestic corporation with principal offices in Towson, Maryland, suffered a loss on its foreign investment in Nippon Black & Decker ("NBD"), during its 1981 tax year when NBD stock became worthless. Black & Decker attempted to offset this loss against its taxable income in the form of a foreign tax credit. In 1988 the Commissioner of Internal Revenue mailed Black & Decker a notice...

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