Blood v. Commissioner

Board of Tax Appeals

Blood v. Commissioner

13 B.T.A. 149, 1928 BTA LEXIS 3304

CourtUnited States Board of Tax Appeals

DecidedJuly 31, 1928

DocketDocket No. 14981.

StatusPublished

Cited by1 cases

This text of 13 B.T.A. 149 (Blood v. Commissioner) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Blood v. Commissioner, 13 B.T.A. 149, 1928 BTA LEXIS 3304 (bta 1928).

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Opinion

OPINION.

ARUndell:

This case was submitted on the petition and answer. The facts are not in dispute. Respondent determined a deficiency in income taxes for the calendar year 1923 ,in the amount of $367.63. The petitioner contests the deficiency only in so far as the respondent has failed to allow a credit against it of the amount of $370 paid to the Government of Canada as an income tax for the year 1919, but not paid by the petitioner until the year 1921. The Commissioner’s disallowance of the credit is based on the fact that under section 222 of the Revenue Act of 1921 only “ taxes paid during the taxable year to any foreign country” may be deducted, and that an income tax paid to Canada in 1921 may not be used as a credit against income taxes due the United States in 1923. Respondent’s determination is correct. Albert D. Hewinson, 1 B. T. A. 1080; David A. Cunningham, 9 B. T. A. 1050.

Judgment will be entered for the respondent.

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OPINION.

ARUndell:

This case was submitted on the petition and answer. The facts are not in dispute. Respondent determined a deficiency in income taxes for the calendar year 1923 ,in the amount of $367.63. The petitioner contests the deficiency only in so far as the respondent has failed to allow a credit against it of the amount of $370 paid to the Government of Canada as an income tax for the year 1919, but not paid by the petitioner until the year 1921. The Commissioner’s disallowance of the credit is based on the fact that under section 222 of the Revenue Act of 1921 only “ taxes paid during the taxable year to any foreign country” may be deducted, and that an income tax paid to Canada in 1921 may not be used as a credit against income taxes due the United States in 1923. Respondent’s determination is correct. Albert D. Hewinson, 1 B. T. A. 1080; David A. Cunningham, 9 B. T. A. 1050.

Judgment will be entered for the respondent.

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13 B.T.A. 149, 1928 BTA LEXIS 3304, Counsel Stack Legal Research, https://law.counselstack.com/opinion/blood-v-commissioner-bta-1928.

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