Keen v. Commissioner
United States Board of Tax Appeals
A tax paid to the Republic of France by a citizen of the United States temporarily residing in France computed upon an estimated income of seven times the rental value of the residence occupied by him is an income tax within the meaning of section 222(a)(1) of the Revenue Act of 1921.
1Opinion of the Court
*1244OPINION.
Smith :
The question herein presented is whether the petitioner is mtitled to a credit against his income tax for 1923 of the tax paid by him in that year to the Republic of France. The respondent contends that the tax paid to the Republic of France is a property tax and not an income tax within the meaning of section 222(a) of the Revenue Act of 1921.
The case of this same petitioner was before the Board for the year 1921 in Herbert Ide Keen, 6 B. T. A. 275. In that case it was stipulated that the tax paid by the petitioner was an income tax and upon the basis of the stipulation the…
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