(U.S. Supreme Court grants certiorari in case to resolve split between U.S. Circuit Courts of Appeal on issue of whether U.K. windfall profits tax paid by plaintiff’s U.K. subsidiary is creditable under I.R.C. §901; Third Circuit held that it was not and Fifth Circuit held that it was; court reversed Third Circuit decision; British utility partly owned by plaintiff U.S. company was privatized between 1984 and 1996 which caused profits and share prices to soar; British Labour party (liberal progressives) imposed windfall profit tax of 23 percent on difference between profit-making value and price at which government sold company; plaintiff claimed credit on 1997 return for "income, war profits, or excess profits taxes" paid to another country pursuant to I.R.C. Sec. 901(b); Tax Court upheld credit and Third Circuit reversed; Court reversed Third Circuit on basis that tax was tax on "excess profits" of privatized utilities; Court noted that U.K. artificially calculated value and tax was nothing more than a tax on profit above a threshold).