§891 — Doubling of rates of tax on citizens and corporations of certain foreign countries

9 cases·9 cited

Whenever the President finds that, under the laws of any foreign country, citizens or corporations of the United States are being subjected to discriminatory or extraterritorial taxes, the President shall so proclaim and the rates of tax imposed by sections 1, 3, 11, 801, 831, 852, 871, and 881 shall, for the taxable year during which such proclamation is made and for each taxable year thereafter, be doubled in the case of each citizen and corporation of such foreign country; but the tax at such doubled rate shall be considered as imposed by such sections as the case may be. In no case shall this section operate to increase the taxes imposed by such sections (computed without regard to this section) to an amount in excess of 80 percent of the taxable income of the taxpayer (computed without regard to the deductions allowable under section 151 and under part VIII of subchapter B). Whenever the President finds that the laws of any foreign country with respect to which the President has made a proclamation under the preceding provisions of this section have been modified so that discriminatory and extraterritorial taxes applicable to citizens and corporations of the United States have been removed, he shall so proclaim, and the provisions of this section providing for doubled rates of tax shall not apply to any citizen or corporation of such foreign country with respect to any taxable year beginning after such proclamation is made.

9 Citing Cases

Larry E. Tucker, Petitioner 135 T.C. No. 6 · 2010

Thus, the issue here is not whether appeals officers are unimportant, but whether they are "Officers of the United States" . - 83 to enforce compliance with discovery orders .'" Id . (quoting Freytag.v. Commisioner , supra at 881-882) . However, unlike the STJs, the ALJs-lacked .the power to. make. final decisions . Id . at 1133.

Tucker v. Commissioner 135 T.C. 114 · 2010
Estate of Leyman v. Commissioner 40 T.C. 100 · 1963
Behl v. Commissioner 7 T.C. 1473 · 1946
Green v. Commissioner 3 T.C. 74 · 1944
United States v. Laboy-Torres 553 F.3d 715 · Cir.
James Daley, Jr. v. Ann Mostoller · Cir.
United States v. Marco Laboy-Torres · Cir.
James Daley, Jr. v. Ann Mostoller 717 F.3d 506 · Cir.