Legal Opinion

Aktiebolaget Separator v. Commissioner

United States Board of Tax Appeals

Decided September 30, 1941No. Docket No. 101328Published

Space rented in United States by petitioner, a foreign corporation, with no purpose of carrying on any part of its manufacturing business therein, but merely for the receipt of dividend income from domestic corporations, held not an "office or place of business" within the United States so as to constitute petitioner a resident foreign corporation within meaning of Revenue Act of 1936, section 231(b).

1Opinion of the Court

AKTIEBOLAGET SEPARATOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Aktiebolaget Separator v. Commissioner

Docket No. 101328.

United States Board of Tax Appeals

45 B.T.A. 243; 1941 BTA LEXIS 1152;

September 30, 1941, Promulgated

Space rented in United States by petitioner, a foreign corporation, with no purpose of carrying on any part of its manufacturing business therein, but merely for the receipt of dividend income from domestic corporations, held not an "office or place of business" within the United States so as to constitute petitioner a resident foreign corporation within…

2Cases cited1 opinion

  1. Aktiebolaget Separator v. CommissionerUnited States Board of Tax Appeals · 1941

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