Bank of America v. United States

This case is before the court on the defendant’s exceptions to the findings of fact and recommended opinion of Trial Judge John P. Wiese. We are faced with the question whether certain commissions received by the plaintiff, Bank of America, an Edge Act corporation, should be characterized as United States or foreign source income for purposes of the Internal Revenue Code. The trial judge held that all the commissions at issue should be classified as income from sources without the United States. We have given careful consideration to the trial judge’s report, the parties’ submissions, and…