Ossorio v. Commissioner
United States Tax Court
The petitioner is a citizen and a resident of the United States and his wife is a citizen and resident of the Philippine Islands.
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The petitioner is a citizen and a resident of the United States and his wife is a citizen and resident of the Philippine Islands. They filed separate income tax returns for 1937 with the Philippine taxing authorities, that of the petitioner showing a net income of 1,399,687.61 pesos ($ 699,848.81) and that of the wife a net income of 235,234.10 pesos ($ 117,617.05). Pursuant to the provisions of the Philippine income tax law, the returns were consolidated for the purpose of computing the tax due from the marital community and a tax of $ 165,763.65 was determined, of which the petitioner paid…
1Opinion of the Court
OPINION.
Smith, Judge:
This is a proceeding for the redetermination of a deficiency of $9,019.10 in income tax for the calendar year 1937. The question in issue is the amount of the credit to which the petitioner is entitled under section 131 of the Revenue Act of 1936 by reason of a payment of income tax for 1937 to the Philippine taxing authorities.
The facts are found as stipulated.
1. The petitioner is a resident of Meads Point, Greenwich, Connecticut. He filed his income tax return for 1937 with the collector of internal revenue for the second district of New York.
2. The petitioner has been…
2Cases cited2 opinions
- Taft v. HelveringSupreme Court of the United States · 1940
- Helvering v. JanneySupreme Court of the United States · 1940
3Cited by4 opinions
- Howell v. CommissionerUnited States Tax Court · 1948
- United States v. RexachDistrict Court, D. Puerto Rico · 1961
- Howell v. CommissionerUnited States Tax Court · 1948
- Ossorio v. CommissionerUnited States Tax Court · 1943