Rowan v. Commissioner of Internal Revenue

HOLMES, Circuit Judge.

The question in this case is whether petitioners were entitled to deduct, in their United States income-tax returns for 1937, income taxes alleged to have accrued to the Republic of Mexico in 1937 which were paid in 1938.

The firm of Rowan and Hope is a domestic partnership which does business in Texas and Mexico. The members of the partnership and their wives filed separate income-tax returns for the calendar year 1937 which included income from the partnership under the community-property law. In those returns a deduction was claimed for income taxes alleged to have…