AMOCO CORPORATION v. COMMISSIONER

Docket No. 20471-92.

71 T.C.M. 2613 (1996)

T.C. Memo. 1996-159

Amoco Corporation (Formerly Standard Oil Company (Indiana)) and Affiliated Corporations v. Commissioner.

United States Tax Court.

Filed March 28, 1996.


Attorney(s) appearing for the Case

Robert L. Moore II, Jay L. Carlson, Emmett B. Lewis, J. Bradford Anwyll, Kevin L. Kenworthy, Laura G. Ferguson, and James J. Lenahan, for the petitioner. William G. Merkle, Cynthia J. Mattson, William B. Lowrance, Paul S. Manning, Michael J. Calabrese, Jan E. Lamartine, Bettie N. Ricca, and Joan M. Thomsen, for the respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

TANNENWALD, Judge:

Respondent determined deficiencies in petitioner's 1980, 1981, and 1982 Federal income taxes in the amounts of $109,618,203, $200,848,534, and $155,776,311, respectively. The issue for decision is whether petitioner is entitled, under section 901,1 to foreign tax credits for Egyptian income taxes purportedly paid or accrued for the years 1979-1982.2...

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