Kelsey v. Commissioner
United States Tax Court
Victory Tax -- Deduction -- State Income Taxes. -- Petitioner, a nonresident of New York State, paid personal income taxes to that state on income derived from business carried on within that state. Held, that such personal income taxes are not deductible from gross income in computing victory tax net income within the intendment of section 451 (a) (3), I. R. C.
1Opinion of the Court
OPINION.
Tyson, Judge:
Respondent has determined against petitioner an income and victory tax deficiency of $332.71 for the calendar year 1943, only a portion of which is in controversy.
The question presented is whether respondent erred in disallowing a deduction by petitioner of New York State tax imposed upon him as a nonresident of that state in the computation of his victory tax net income.
The proceeding was submitted on the pleadings and a stipulation of facts. The facts stipulated are so found and are included herein by reference.
Petitioner is an attorney, engaged in the practice of law…
2Cases cited9 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Lyeth v. HoeySupreme Court of the United States · 1938
- Shaffer v. CarterSupreme Court of the United States · 1920
- United States v. PelzerSupreme Court of the United States · 1941
- Travis v. Yale & Towne Manufacturing Co.Supreme Court of the United States · 1920
4 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Alexander v. CommissionerUnited States Tax Court · 1955
- Alexander v. CommissionerUnited States Tax Court · 1955
- Kelsey v. CommissionerUnited States Tax Court · 1950