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NEW YORK & HONDURAS ROSARIO MINING CO. v. COMMISSIONER

Docket No. 8940.

8 T.C. 1232 (1947)

NEW YORK AND HONDURAS ROSARIO MINING CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 23, 1947.

Attorney(s) appearing for the Case

Francis D. Murray, Esq., for the petitioner.

Walt Mandry, Esq., for the respondent.

The Commissioner determined deficiencies of $22,561.51 and $32,516.36 in petitioner's income taxes for 1941 and 1942, respectively, in part by disallowing as a credit amounts paid as taxes in those years to the Republic of Honduras. Petitioner contends that the amounts were income taxes and are hence credits under sections 131, Internal Revenue Code, or, in the alternative, that they are deductible under section 23 (c).

OPINION...

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