Anglo-American Direct Tea Trading Co. v. Commissioner
United States Board of Tax Appeals
A foreign corporation receiving income from sources within the United States, which filed its income tax returns "in the manner prescribed" under Title I of the Revenue Acts of 1928 and 1932, is not precluded under the provisions of section 233 of the same acts from the benefit of the deduction to which it is entitled under section 23(p)(1) of the same acts, although it filed its returns after the time specified in section 235 thereof.
1Opinion of the Court
*713OPINION.
Mellott :
It is not disputed that the petitioner received gross income from sources within the United States during the fiscal years before us, and that such income consisted of dividends received from the American Co. in the amounts shown in the findings. There is also no question that section 23 (p) (1) of the Revenue Act of 19281 and the corresponding sections of the act of 19322 permit the deduction of dividends from gross income of either a domestic or foreign corporation. The sufficiency in content of the returns is not challenged.
The respondent points out that the deductions…
2Cases cited15 opinions
- Gould v. GouldSupreme Court of the United States · 1917
- United States v. MerriamSupreme Court of the United States · 1923
- Bankers Life Insurance v. RobbinsNebraska Supreme Court · 1899
- People Ex Rel. Williams Engineering & Contracting Co. v. MetzNew York Court of Appeals · 1908
- United States v. MorrisU.S. Circuit Court for the District of Massachusetts · 1851
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3Cited by13 opinions
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- Anglo-American Direct Tea Trading Co. v. CommissionerUnited States Board of Tax Appeals · 1938
- Ardbern Co. v. CommissionerUnited States Board of Tax Appeals · 1940
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