Legal Opinion

Chang Hsiao Liang v. Commissioner

United States Tax Court

Decided March 18, 1955No. Docket No. 43978Published

Petitioner, a nonresident alien whose securities were managed primarily for investment purposes by a resident commission agent, held, on facts, not subject to tax on capital gains as not being engaged in a trade or business within the United States under section 211 (b), Internal Revenue Code of 1939.

1Opinion of the Court

Chang Hsiao Liang, Petitioner, v. Commissioner of Internal Revenue, Respondent

Chang Hsiao Liang v. Commissioner

Docket No. 43978

United States Tax Court

23 T.C. 1040; 1955 U.S. Tax Ct. LEXIS 223;

March 18, 1955, Filed

Decision will be entered for the petitioner.

Petitioner, a nonresident alien whose securities were managed primarily for investment purposes by a resident commission agent, held, on facts, not subject to tax on capital gains as not being engaged in a trade or business within the United States under section 211 (b), Internal Revenue Code of 1939.

D. Nelson Adams, Esq., and Frank H.…

2Cases cited7 opinions

  1. Higgins v. CommissionerSupreme Court of the United States · 1941
  2. Commissioner of Internal Revenue v. NubarCourt of Appeals for the Fourth Circuit · 1950
  3. Adda v. CommissionerUnited States Tax Court · 1948
  4. Kane v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1938
  5. Nubar v. CommissionerUnited States Tax Court · 1949

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