Legal Opinion
Joseph Van Der Elst v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided June 21, 1955No. 23037_1PublishedCited by 10 opinions
1Opinion of the Court
SWAN, Circuit Judge.
This appeal involves the petitioner’s income tax for the year 1946. Under the provisions of section 211(b), as amended, of the Internal Revenue Code, 26 U.S.C.A. § 211(b), the petitioner, Baron Van Der Elst, has been taxed as a nonresident alien engaged in trade or business in the United States during the first six months of 1946. He contends (1) that he was not so engaged, and (2) that in any event he was not subject to tax on capital gains realized after his departure from the United States on or about June 30, 1946.
The memorandum findings of fact and opinion of the Tax…
2Cases cited3 opinions
- Goldring v. CommissionerUnited States Board of Tax Appeals · 1937
- Jamvold v. CommissionerUnited States Tax Court · 1948
- Steur v. CommissionerUnited States Tax Court · 1946
3Cited by10 opinions
- John M. Trent and Lisa M. Trent v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
- Simenon v. CommissionerUnited States Tax Court · 1965
- Advance Transformer Co. v. Superior CourtCalifornia Court of Appeal · 1974
- Ying v. CommissionerUnited States Tax Court · 1992
- de Vegvar v. CommissionerUnited States Tax Court · 1957
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