Legal Opinion
Commissioner of Internal Rev. v. PIEDRAS NEGRAS B. CO.
Court of Appeals for the Fifth Circuit
Decided April 3, 1942No. 10035PublishedCited by 17 opinions
1Opinion of the Court
HOLMES, Circuit Judge.
The respondent is a corporation organized under the laws of the State of Coahuila, Republic of Mexico, with its principal office and place of business at Piedras Negras, Mexico. Its business is the operation of a radio broadcasting station located at Piedras Negras, just across the Rio Grande from Eagle Pass, Texas. The decisive question presented by this petition for review is whether the respondent, from the operation of its business in 1936 and 1937, derived any income from sources within the United States subject to taxation by the United States.
The taxpayer…
2Cases cited3 opinions
- Commissioner of Internal Revenue v. East Coast Oil Co.Court of Appeals for the Fifth Circuit · 1936
- Helvering v. SteinCourt of Appeals for the Fourth Circuit · 1940
- Commissioner of Int. Rev. v. Hawaiian Philippine Co.Court of Appeals for the Ninth Circuit · 1939
3Cited by17 opinions
- John Factor v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
- Stemkowski v. CommissionerUnited States Tax Court · 1981
- West Publishing Co. v. McColganCalifornia Supreme Court · 1946
- Barraclough v. State Tax CommissionIdaho Supreme Court · 1954
- American Food Products Corp. v. CommissionerUnited States Tax Court · 1957
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