United States Tax Court August 6, 1968, Docket Nos. 4170-66, 4171-66 (Grunebaum v. Commissioner)

lead-opinion

OniNIOST

Raum, Judge:

Section 901 of the Internal Revenue Code of 1954 entitles a taxpayer, if he so elects, to credit directly against his income tax certain taxes paid to foreign countries or possessions of the United States, “subject to the applicable limitation of section 904.