Robillard v. Commissioner
United States Board of Tax Appeals
1. FOREIGN INCOME TAX. - Where dividends are received by a citizen of the United States, a resident therein, on stock which he holds in a foreign corporation, a holding company, he is not entitled to credit against the tax on such dividends foreign taxes which were paid at the source for the account of the foreign corporation, a holding corporation, and not for the account of the stockholder. 2. RULING OF COMMISSIONER IN A PRIOR YEAR. - The fact that the Commissioner allowed…
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1. FOREIGN INCOME TAX. - Where dividends are received by a citizen of the United States, a resident therein, on stock which he holds in a foreign corporation, a holding company, he is not entitled to credit against the tax on such dividends foreign taxes which were paid at the source for the account of the foreign corporation, a holding corporation, and not for the account of the stockholder. 2. RULING OF COMMISSIONER IN A PRIOR YEAR. - The fact that the Commissioner allowed the credit in a prior year does not preclude his disallowing it in the taxable years, if his former action was…
1Opinion of the Court
BASIL ROBILLARD, EXECUTOR, ESTATE OF MARTHA H. BEEMAN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Robillard v. Commissioner
Docket Nos. 44008, 45835.
United States Board of Tax Appeals
20 B.T.A. 685; 1930 BTA LEXIS 2057;
September, 8, 1930, Promulgated
1. FOREIGN INCOME TAX. - Where dividends are received by a citizen of the United States, a resident therein, on stock which he holds in a foreign corporation, a holding company, he is not entitled to credit against the tax on such dividends foreign taxes which were paid at the source for the account of the foreign corporation, a…
2Cases cited1 opinion
- Robillard v. CommissionerUnited States Board of Tax Appeals · 1930