
    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.
   DECISION.

The determination of the Commissioner is approved, in accordance with section 222 (a) (1), Revenue Act of 1921.  