United States Court of Claims March 3, 1941, 44071 (Third Scottish American Trust Co. v. United States)

WHITAKER, Judge.

I. The plaintiff is a foreign corporation chartered under the laws of Great Britain. During the year 1933 it derived income from sources within the United States eon,

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sisting of interest and dividends. It seeks to deduct from such gross income a “ratable part” of its home office expenses, interest and British income taxes.