Peterson v. Commissioner
United States Board of Tax Appeals
In connection with the conduct of a lottery the Government of Newfoundland assessed against and collected from a certain veterans' organization in Canada an income tax on the proceeds of the lottery.
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In connection with the conduct of a lottery the Government of Newfoundland assessed against and collected from a certain veterans' organization in Canada an income tax on the proceeds of the lottery. Held that, the tax having been one imposed upon and paid by the veterans' organization, the petitioner, a holder of a ticket entitling him to share in certain proceeds of the lottery, is not entitled to a credit against his income tax liability owing to the United States, of a proportional part of the tax paid by the veterans' organization.
1Opinion of the Court
OPINION.
Trammell:
This proceeding is for the redetermination of a deficiency in income tax of $8,851.14 for 1931. The only matter in con: troversy is the correctness of the respondent’s action in refusing to *173allow as a credit against the petitioner’s tax liability an amount of $11,801.52 which it is alleged represents income tax of the petitioner paid to the Government of Newfoundland. The proceeding was submitted upon a stipulation of facts and certain documentary evidence.
Pertinent portions of the stipulation are as follows:
The petitioner is a citizen of the United States who at all times…
2Cases cited2 opinions
- Robillard v. CommissionerUnited States Board of Tax Appeals · 1930
- Duckworth Co. v. CommissionerUnited States Board of Tax Appeals · 1931
3Cited by2 opinions
- Badger Co. v. CommissionerUnited States Tax Court · 1967
- Peterson v. CommissionerUnited States Board of Tax Appeals · 1934