Dexter v. Commissioner
United States Board of Tax Appeals
All of petitioners' income was derived from sources within the Philippine Islands, to the Government of which petitioners paid income tax. Petitioners had no income from sources within the United States. Petitioners' net income under the revenue law of the Philippines was greater than their net income under the revenue law of the United States, so that the income tax paid to the Philippine Government was greater than the income tax due the United States.
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All of petitioners' income was derived from sources within the Philippine Islands, to the Government of which petitioners paid income tax. Petitioners had no income from sources within the United States. Petitioners' net income under the revenue law of the Philippines was greater than their net income under the revenue law of the United States, so that the income tax paid to the Philippine Government was greater than the income tax due the United States. Petitioners' income from sources outside the United States was from sources within the Philippines, only. Held, under the plain wording of…
1Opinion of the Court
*288OPINION.
Harron:
The petitioners claim that the amount of the credit for income tax paid and accrued to the Government of the Philippine Islands in 1936 should be the entire amount of that tax, $16,542.60. If that contention is sound, the total United States income tax in the amount of $9,073.01 will be offset by the Philippine tax and there will be no deficiency. The respondent argues that under section 131 (b) of the Revenue Act of 1936 the amount of the credit for the Philippine tax is less than the amount of the United States tax, under his original formula, and that his arithmetical…
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