United States DC Circuit

Official tax receipts that a Brazilian bank submitted to the Brazilian government, on behalf of appellant U.S. bank, are entitled to the presumption of regularity, and where the Commissioner of Internal Revenue failed to show that the taxes had not been paid, appellant is entitled to foreign tax credits.

Appellate Information

• Argued 03/15/2002
• Decided 07/12/2002
• Published 07/12/2002

Judges

• Before:  SENTELLE, HENDERSON and TATEL, Circuit Judges.

Court

• United States DC Circuit

Counsel

• For Appellant:
  
• Thomas C. Durham argued the cause for appellant.   With him on the briefs were Joel V. Williamson, Russell R. Young, Kim Marie Boylan, Charles W. Hall and Stephen M. Feldhaus., Stephen D. Gardner was on the brief for amicus curiae National Foreign Trade Council, Inc. in support of appellant.


• For Appellees:
  
• Charles Bricken, Attorney, U.S. Department of Justice, argued the cause for appellee.   With him on the brief was David English Carmack, Attorney.