Kelsey v. Commissioner
United States Tax Court
Victory Tax -- Deduction -- State Income Taxes. -- Petitioner, a nonresident of New York State, paid personal income taxes to that state on income derived from business carried on within that state. Held, that such personal income taxes are not deductible from gross income in computing victory tax net income within the intendment of section 451 (a) (3), I. R. C.
1Opinion of the Court
Courtland Kelsey, Petitioner, v. Commissioner of Internal Revenue, Respondent
Kelsey v. Commissioner
Docket No. 16335
United States Tax Court
14 T.C. 107; 1950 U.S. Tax Ct. LEXIS 289;
January 30, 1950, Promulgated
Decision will be entered under Rule 50.
Victory Tax -- Deduction -- State Income Taxes. -- Petitioner, a nonresident of New York State, paid personal income taxes to that state on income derived from business carried on within that state. Held, that such personal income taxes are not deductible from gross income in computing victory tax net income within the intendment of section 451 (a)…
2Cases cited10 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Lyeth v. HoeySupreme Court of the United States · 1938
- Shaffer v. CarterSupreme Court of the United States · 1920
- United States v. PelzerSupreme Court of the United States · 1941
- Travis v. Yale & Towne Manufacturing Co.Supreme Court of the United States · 1920
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