Legal Opinion
District of Columbia v. Upjohn Co.
Court of Appeals for the D.C. Circuit
Decided November 22, 1950No. 10542_1PublishedCited by 2 opinions
1Opinion of the Court
PRETTYMAN, Circuit Judge.
This is a petition to review a decision of the Board of Tax Appeals for the District of Columbia in an income tax case involving the years 1943-46. The question is whether the income from certain sales was or was not from sources within the District of Columbia. 1
It is established in this jurisdiction that, absent contrary statutory definition, the source of income from sales is the place at which title to the property passes. 2 The question in the present case is where the title to the goods passed.
Respondent is a manufacturer of pharmaceuticals and chemicals, with…
2Cases cited7 opinions
- A. J. Neimeyer Lumber Co. v. Burlington & Missouri River RailroadNebraska Supreme Court · 1898
- District of Columbia v. Chesapeake & Potomac Telephone Co.Court of Appeals for the D.C. Circuit · 1950
- Banque De France v. Chase Nat. Bank of City of New YorkCourt of Appeals for the Second Circuit · 1932
- District of Columbia v. Johnson & Wimsatt, Inc.Court of Appeals for the D.C. Circuit · 1947
- Electric Storage Battery Co. v. District of ColumbiaDistrict Court, District of Columbia · 1946
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3Cited by2 opinions
- United States v. Ligia Maria Valencia Gaviria and Martha Lucia Bedoya LopezCourt of Appeals for the Second Circuit · 1984
- Heath v. United StatesCourt of Appeals for the Ninth Circuit · 1954