Heffelfinger v. Commissioner
United States Tax Court
Petitioner, an individual American citizen, on a calendar year cash basis, paid Canadian income taxes in 1941 which were imposed on his Canadian income for 1939 and 1940, during each of which years he was a nonresident of the United States for more than 6 months.
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Petitioner, an individual American citizen, on a calendar year cash basis, paid Canadian income taxes in 1941 which were imposed on his Canadian income for 1939 and 1940, during each of which years he was a nonresident of the United States for more than 6 months. Held, petitioner is limited in his deduction of such Canadian income taxes for United States income tax purposes in 1941 by section 24 (a) (5) of the Internal Revenue Code, as validly construed for present purposes in Regulations 103, section 19.24-4.
1Opinion of the Court
OPINION.
Leecii, Judge-.
Respondent determined a deficiency of $5,879.92 in income taxes against petitioner for the calendar year 19-11. In the income tax return of petitioner for that year he deducted the entire amount of $24,898.14 for income taxes paid to the Dominion of Canada during such j'ear. Respondent disallowed $15,807.13 of this amount under sections 24 and 116 of the Internal Revenue Code. The propriety of that action presents the only issue. We find the facts to be as stipulated. The stipulation follows:
1. Petitioner is an individual whose business address is 312 Chamber of…
2Cases cited3 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
- White v. United StatesSupreme Court of the United States · 1938
3Cited by12 opinions
- Hawaiian Trust Company Limited v. United StatesCourt of Appeals for the Ninth Circuit · 1961
- Stallforth v. CommissionerUnited States Tax Court · 1946
- Hawaiian Trust Co. v. United StatesCourt of Appeals for the Ninth Circuit · 1961
- W. Horace Williams Co. v. CocrehamSupreme Court of Louisiana · 1948
- Hempel v. CommissionerUnited States Tax Court · 1947
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