Biddle v. Commissioner of Internal Revenue

MANTON, Circuit Judge.

The petitioner seeks a review of a decision of the Board of Tax Appeals holding that the only amount of income taxable to her as dividends received from shares of stock which she owned in two British corporations is the net amount of cash actually received as dividends. A further question presented is whether an amount treated as British income taxes “appropriate to” the dividends paid may be partially taken as a credit against petitioner’s income tax under section 131 (a) (b) of the Revenue Act of 1928 (45 Stat. 791 [26 U.S.C.A. § 131 and note]) and the balance deducted…