CONTINENTAL OIL CO. ET AL.

v.

MINNESOTA

Citator

Cited By

• Mo. Pac. R.R. Co. v. The United States, 392 F.2d 592 (Ct. Cl. 1968)
  …hose deductions which cannot reasonably be directly assigned to one country or the other should be allocated ratably between the two. International Standard Elec. Corp. v. Commissioner of Internal Revenue, 144 F. 2d 487 (2d Cir. 1944), cert. denied, 323 U.S. 803, 65 S.Ct. 560, 89 L.Ed. 640 (ratably allocating to foreign countries part of the general or overhead expenses of a domestic holding company which received dividend income from foreign subsidiaries in those countries). Since determining net taxable…
• Fahey v. Calverley, 208 F.2d 197 (9th Cir. 1953)
  …tion. This Court’s previous decisions in this matter require not only the dismissal of the principal pleadings and proceedings, but also the dismissal of matters ancillary thereto. Oils, Inc. v. Blankenship, 10 Cir., 145 F. 2d 354, certiorari denied 323 U.S. 803, 65 S.Ct. 562, 89 L.Ed. 641; Cabaniss v. Reco Min. Co., 5 Cir., 116 F. 318. It appears that the aforesaid special master was appointed in the said consolidated proceedings to perform functions which it has now been determined were beyond the power…
• Mo. Pac. R.R. Co. v. United States, 411 F.2d 327 (8th Cir. 1969)
  …ductions which cannot reasonably be directly assigned to one country or the other [*329] should be allocated ratably between the two. International Standard Elec. Corp. v. Commissioner of Internal Revenue, 144 F. 2d 487 (2d Cir. 1944), cert. denied, 323 U.S. 803, 65 S.Ct. 560, 89 L.Ed. 640 * * * ” The government computed the taxpayer’s Mexican net income as follows: Gross Income 1955 $1,048,838 1956 $1,100,872 Deductions $653,981 $685,534 Net Income From Mexico $394,856 $415,338 The taxpayer’s income tax…