1. Home
  2. Browse Decisions
  3. F.3d
  4. 665 F.3d
  5. 665 F.3d 60 (2011)
 

PPL CORP. v. C.I.R.

No. 11-1069.

665 F.3d 60 (2011)

PPL CORPORATION and Subsidiaries v. COMMISSIONER OF INTERNAL REVENUE, Appellant.

United States Court of Appeals, Third Circuit.

Opinion filed: December 22, 2011.

Attorney(s) appearing for the Case

Thomas J. Clark, Esquire , Gilbert S. Rothenberg, Esquire , Francesca U. Tamami, Esquire (Argued), United States Department of Justice, Tax Division, Washington, DC, for Appellant.

Mark B. Bierbower, Esquire , Timothy L. Jacobs, Esquire , Richard E. May, Esquire (Argued), Hunton & Williams LLP, Washington, DC, for Appellee.

Alan I. Horowitz, Esquire , Miller & Chevalier Chartered, Washington, DC, for Amicus Appellee.

Before: AMBRO, CHAGARES and GARTH, Circuit Judges.

OPINION OF THE COURT

AMBRO, Circuit Judge.

The Commissioner of Internal Revenue appeals a decision of the United States Tax Court holding that PPL Corporation was entitled to a foreign tax credit for the 1997 tax year under § 901 of the Internal Revenue Code. We agree with the Commissioner that the foreign tax before us does not qualify for a foreign tax credit, and thus reverse.

I. Background

PPL is a Pennsylvania corporation. In...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases