Legal Opinion

Briskey Co. v. Commissioner

United States Board of Tax Appeals

Decided February 2, 1934No. Docket No. 60899Published

Petitioner, a domestic corporation, maintained a branch in India which purchased and shipped skins to fill orders transmitted to it through the home office in the United States. Some shipments were made directly to the purchasers and others to the home office for the account of the purchasers. The India branch fixed the prices and collected for skins shipped by drawing on letters of credit.

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Petitioner, a domestic corporation, maintained a branch in India which purchased and shipped skins to fill orders transmitted to it through the home office in the United States. Some shipments were made directly to the purchasers and others to the home office for the account of the purchasers. The India branch fixed the prices and collected for skins shipped by drawing on letters of credit. Held, the sales were consummated in India and the income was from sources without the United States; hence petitioner is entitled to credit for foreign income taxes on such income. Section 131, Revenue Act…

1Opinion of the Court

BRISKEY COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Briskey Co. v. Commissioner

Docket No. 60899.

United States Board of Tax Appeals

29 B.T.A. 987; 1934 BTA LEXIS 1441;

February 2, 1934, Promulgated

Petitioner, a domestic corporation, maintained a branch in India which purchased and shipped skins to fill orders transmitted to it through the home office in the United States. Some shipments were made directly to the purchasers and others to the home office for the account of the purchasers. The India branch fixed the prices and collected for skins shipped by drawing on…

2Cases cited1 opinion

  1. Briskey Co. v. CommissionerUnited States Board of Tax Appeals · 1934

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