Tax

Appeal of ALBERT D. HEWINSON

1 B.T.A. 1080·United States Board of Tax Appeals·1925

Before SteRNiiagen, Trammell, and Phillips.

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Opinion

Appeal of ALBERT D. HEWINSON. Docket No. 1549. Submitted April 1, 1925; decided April 29, 1925. Robert A. Littleton, Esq., for the Commissioner. Before SteRNiiagen, Trammell, and Phillips. The amount of deficiency asserted and in controversy is $35.58, income tax for the year 1923. FINDINGS OF FACT. The taxpayer is a citizen of the United States, but is domiciled in the Dominion of Canada. He kept his books on a cash receipts and disbursements basis. In April, 1924, he paid the Dominion of Canada the sum of $43.20, income tax due for the year 1923. The Commissioner refused to allow this payment as a credit for the year 1923. [MAJORITY] DECISION. The determination of the Commissioner is approved, in accordance with section 222 (a) (1), Revenue Act of 1921.