RIGGS NATL. CORP. & SUBS. v. COMMISSIONER

Docket No. 24368-89.

107 T.C. 301 (1996)

RIGGS NATIONAL CORPORATION & SUBSIDIARIES (F.K.A. RIGGS NATIONAL BANK AND SUBSIDIARIES), PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 10, 1996.


Attorney(s) appearing for the Case

Joel V. Williamson, Thomas C. Durham, Scott M. Stewart, Richard M. Timmel, Patricia Anne Flaming, and Kim Marie Boylan, for petitioner.

Theodore J. Kletnick, William G. Merkle, Diane P. Thaler, Paul S. Manning, Rajiv Madan, Mary Ann Amodeo, and Janice E. Lamartine, for respondent.


JACOBS, Judge:

Respondent determined deficiencies in the Federal income tax of petitioner Riggs National Corp. & Subsidiaries, formerly known as Riggs National Bank & Subsidiaries.

The dispute involves petitioner's entitlement to foreign tax credit under section 9011 for Brazilian taxes withheld on interest income petitioner received, during the years 1980 through 1986, as a result of its loans to Brazilian borrowers...

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