Billwiller v. Commissioner
United States Board of Tax Appeals
1. NONRESIDENT ALIEN. - A nonresident alien individual who, in association with others, derives gains and profits from the sale, within the United States, of merchandise manufactured without the United States is liable to the United States for income tax upon such gains and profits.
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1. NONRESIDENT ALIEN. - A nonresident alien individual who, in association with others, derives gains and profits from the sale, within the United States, of merchandise manufactured without the United States is liable to the United States for income tax upon such gains and profits. Richard L. Birkin,5 B.T.A. 402. 2. COST OF GOODS SOLD. - The respondent has accepted the books of account kept on behalf of the petitioner's decedent and his associates at their New York office as showing the cost of goods sold in the United States. Evidence offered on behalf of the petitioner held insufficient to…
1Opinion of the Court
*844OPINION.
Trussell :
The time covered by the two proceedings here under consideration began on May 1, 1918, and ended on April 30, 1920. Any tax liability incurred by the petitioner’s decedent is therefore governed by the provisions of the Revenue Act of 1918, where the gross income of individuals is defined and described in section 213, and that part of said section referring to nonresident aliens is as follows:
*845(c) In the case of nonresident alien individuals, gross income includes only the gross income from sources within the United States, including interest on bonds, notes, or other…
2Cited by1 opinion
- Billwiller v. CommissionerUnited States Board of Tax Appeals · 1928