The opinion
Appeal of ALBERT D. HEWINSON.
Hewinson v. Commissioner
Docket No. 1549.
United States Board of Tax Appeals
1 B.T.A. 1080 ; 1925 BTA LEXIS 2676 ;
April 29, 1925 , decided Submitted April 1, 1925 .
*2676 Robert A. Littleton, Esq., for the Commissioner.
*1080 Before STERNHAGEN, 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 *1081 Commissioner refused to allow this payment as a credit for the year 1923.
DECISION.
The determination of the Commissioner is approved, in accordance with section 222(a)(1), Revenue Act of 1921.