In Re Billings' Protest

This is an appeal by an individual taxpayer from an order of the Oklahoma Tax Commission denying a certain item claimed as a credit on her net income as shown by her income tax return for the year 1937.

The item in question consisted of dividends received from a foreign corporation. The controversy arises under the income tax statutes of 1935 (art. 6, ch. 66, S. L. 1935), and particularly section 11 thereof, the material portion of which reads as follows:

“There shall be allowed, for the purpose of the tax levied under section 6, the following credits against the net income:

“(a) The amount…