Brown v. Commissioner

Board of Tax Appeals

Brown v. Commissioner

1 B.T.A. 446, 1925 BTA LEXIS 2920

CourtUnited States Board of Tax Appeals

DecidedJanuary 30, 1925

DocketDocket No. 537.

StatusPublished

Cited by1 cases

This text of 1 B.T.A. 446 (Brown 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

Brown v. Commissioner, 1 B.T.A. 446, 1925 BTA LEXIS 2920 (bta 1925).

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Opinion

OPINION.

Ivins :

The taxpayer has been misled by the fact that the units of Canadian and American currency are both designated as dollars, and that in normal times they both represent the same amount of gold, with a result that exchange is ordinarily at par. But during the war and for some time thereafter, Canadian currency was at a discount, and when the taxpayer paid to the Canadian Government $764.40 in Canadian money, he only reduced his assets to the extent of $670.13 in American money, if the payment to the Canadian Government had been in pounds sterling, in francs, or in yen, it would be perfectly obvious that the credit permissible against American taxes would be the value in United States dollars of the number of pounds, francs, or yen paid at the time of payment, and the same is equally true with respect to any other foreign currency, even though it happened to be designated “ dollar ” and have a par value identical with that of the United States dollar.

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OPINION.

Ivins :

The taxpayer has been misled by the fact that the units of Canadian and American currency are both designated as dollars, and that in normal times they both represent the same amount of gold, with a result that exchange is ordinarily at par. But during the war and for some time thereafter, Canadian currency was at a discount, and when the taxpayer paid to the Canadian Government $764.40 in Canadian money, he only reduced his assets to the extent of $670.13 in American money, if the payment to the Canadian Government had been in pounds sterling, in francs, or in yen, it would be perfectly obvious that the credit permissible against American taxes would be the value in United States dollars of the number of pounds, francs, or yen paid at the time of payment, and the same is equally true with respect to any other foreign currency, even though it happened to be designated “ dollar ” and have a par value identical with that of the United States dollar.

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1 B.T.A. 446, 1925 BTA LEXIS 2920, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-commissioner-bta-1925.

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