Burk Bros. v. Commissioner
United States Board of Tax Appeals
FOREIGN INCOME TAX - CREDIT. - Where petitioner bought raw materials in India and transported them to this country, where they were manufactured and sold, petitioner is not entitled, under section 238(a) of the Revenue Act of 1926, to have allowed income taxes paid the Indian Government as credits against United States income taxes, because petitioner's entire income was derived from sources within the United States.
1Opinion of the Court
OPINION.
Black:
Respondent has asserted against petitioner deficiencies as follows:
1924_' $2, 506. 28
1925_ 6, 256.47
Total_ 8, 762. 75
and from this determination petitioner has appealed and urges only one error and that one is against the determination for the year 1925. Petitioner alleges that it paid in that year a foreign income tax *658amounting to $4,340.52 to India, and is entitled under section 238(a) of the Revenue Act of 1926 to use the same as a credit against the tax which is due the United States.
Respondent contests the right of petitioner to use such amount as a credit against its tax,…
2Cited by2 opinions
- Briskey Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Burk Bros. v. CommissionerUnited States Board of Tax Appeals · 1930