Elkins v. Commissioner

BUFFINGTON, Circuit Judge.

The petitioner, a citizen of the United States, residing in Pennsylvania, filed his federal income lax return for 1931. It disclosed credits and deductions by reason of taxes deducted and paid directly to the United Kingdom by companies from dividends on stock owned by him. During the year, by reason of his stock holdings in British companies, he received the net amount of $23,993.72 in dividends, such dividends being accompanied by certifica*536tion that $7,017.11 had been deducted and paid directly to the British Government.1

Under authority of section 131 (a) (b) of…