Tootal Broadhurst Lee Co. v. Commissioner
United States Board of Tax Appeals
When goods are manufactured abroad by a foreign corporation and sold in this country, the entire profit constitutes "gross income from sources within the United States," within the meaning of section 233(b) of the Revenue Act of 1918.
1Opinion of the Court
*322OPINION.
Littleton :
The issue is whether income derived by a foreign corporation from the sale in the United States of merchandise manufactured without the United States is income from sources within the United States under section 233(b) of the Revenue Act of 1918, which provides as follows:
In the case of a foreign corporation gross income includes only the gross income from sources within the United States, including the interest on bonds, notes, or other interest-bearing obligations of residents, corporate or otherwise,-dividends from resident corporations, and including all amounts…
2Cases cited2 opinions
- Barclay & Co. v. EdwardsSupreme Court of the United States · 1925
- National Paper & Type Co. v. BowersSupreme Court of the United States · 1924
3Cited by5 opinions
- United States v. BalanovskiCourt of Appeals for the Second Circuit · 1956
- United States v. BalanovskiCourt of Appeals for the Second Circuit · 1956
- Briskey Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- East Coast Oil Co., S. A. v. CommissionerUnited States Board of Tax Appeals · 1934
- Tootal Broadhurst Lee Co. v. CommissionerUnited States Board of Tax Appeals · 1927