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AMOCO CORP. v. C.I.R.

No. 96-3632.

138 F.3d 1139 (1998)

AMOCO CORPORATION (formerly Standard Oil Company (Indiana)) and Affiliated Corporations, Petitioner-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Seventh Circuit.

Decided March 11, 1998.

Attorney(s) appearing for the Case

James J. Lenahan, Chicago, IL, Jay L. Carlson, Alan I. Horowitz, Robert L. Moore, II (argued), Miller & Chevalier, Washington, DC, for Petitioner-Appellee.

Stuart L. Brown, Cynthia J. Mattson, Internal Revenue Service, Gary R. Allen, David E. Carmack, Charles Bricken (argued), Department of Justice, Tax Division, Appellate Section, Loretta C. Argrett, Department of Justice, Tax Division, Washington, DC, for Respondent-Appellant.

Before RIPPLE, KANNE, and DIANE P. WOOD, Circuit Judges.

DIANE P. WOOD, Circuit Judge.

The Internal Revenue Code permits U.S. taxpayers who have paid the equivalent of income taxes to foreign governments to credit those amounts against their U.S. taxes, with certain limitations. See Internal Revenue Code of 1986 § 901 et seq., 26 U.S.C. § 901 et seq.; Internal Revenue Code of 1954 § 901 et seq., 26 U.S.C. § 901 et seq. (1982).1 We must decide in...

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