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NORTHERN IND. PUB. SERV. CO. & SUBS. v. COMMISSIONER

Docket No. 24468-91.

101 T.C. 294 (1993)

NORTHERN INDIANA PUBLIC SERVICE COMPANY AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 7, 1993.

Attorney(s) appearing for the Case

David C. Jensen, William F. Indoe, Andrew P. Solomon, and Lawrence H. Jacobson, for petitioner.

Elsie Hall and Reid M. Huey, for respondent.

OPINION

RUWE, Judge:

Section 14411 requires a payor to withhold income tax on certain types of income paid to nonresident alien individuals. The items of income referred to in section 1441, which include interest, are subject to withholding "to the extent that any of such items constitutes gross income from sources within the United States". Sec. 1441(a) (emphasis added...

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