Hygienic Products Co. v. Commissioner of Internal Revenue

ARANT, Circuit Judge.

The only question presented by this petition is whether income taxes due the Dominion of Canada for the taxable years 1930, 1931, 1932 and 1933, and paid in 1934, are deductible from income taxes due the United States for the taxable year 1934. The Commissioner disallowed the deduction and determined a deficiency; and the Board of Tax Appeals has approved that' determination. Practically all the facts are stipulated.

Section 31 of the Revenue Act of 1934, 26 U.S.C.A.Int.Rev.Code, § 31, provides for credit upon income tax due the United States of income taxes imposed by…