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W. K. BUCKLEY, INC. v. COMMISSIONER OF INTERNAL REV.

No. 17, Docket 20212.

158 F.2d 158 (1946)

W. K. BUCKLEY, Inc., v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

November 18, 1946.

Attorney(s) appearing for the Case

Nixon, Hargrave, Middleton & Devans, of Rochester, (Scott Stewart, Jr. and Thomas C. Taylor, both of Rochester, N. Y., of counsel), for petitioner.

J. P. Wenchel, of Washington, D. C. (Douglas W. McGregor, of Houston, Tex., Sewall Key, J. Louis Monarch and S. Dee Hanson, all of Washington, D. C., of counsel), for respondent.

Before L. HAND, SWAN and FRANK, Circuit Judges.

FRANK, Circuit Judge.

The question for decision is whether the taxpayer made a binding election to claim the foreign taxes as a deduction from gross income under § 23(c) (2) so that it could not later use them as a credit under § 131(a) (1) after the Commissioner audited the return and determined a deficiency, despite the fact that before the audit taxpayer believed that it owed no tax under either of the alternative methods, so that it then believed that...

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