Legal Opinion

Billwiller's Estate v. Commissioner of Internal Revenue

Court of Appeals for the Second Circuit

Decided March 4, 1929No. 240PublishedCited by 3 opinions

1Per curiam

A nonresident alien, who is a member of a foreign partnership which manufactures abroad and sells its product in this country, is subject to an income tax under the Revenue Act of 1918, §§ 213(c), 214(b), and 218(a). 40 Stat. 1066, 1069, 1070. See Tootal-Broadhurst-Lee Co. v. Commissioner of Internal Revenue, 30 F.(2d) 239 (C. C. A. 2, Jan. 7, 1929).

The appeal was argued upon the assumption that the profit from American sales was incorrectly determined, because the figure taken as representing the cost of the goods sold was not their actual cost, but was an invoice value ascribed to them for…

2Cases cited3 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. Rouss v. BowersCourt of Appeals for the Second Circuit · 1929
  3. Tootal Broadhurst Lee Co. v. CommissionerCourt of Appeals for the Second Circuit · 1929

3Cited by3 opinions

  1. Eastman Kodak Co. v. District of ColumbiaDistrict Court, District of Columbia · 1942
  2. Schwerin v. CommissionerDistrict Court, District of Columbia · 1944
  3. Commissioner of Internal Revenue v. BanfieldCourt of Appeals for the Ninth Circuit · 1941

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