Legal Opinion

Billwiller v. Commissioner

United States Board of Tax Appeals

Decided April 26, 1928No. Docket Nos. 8313, 8314Published

1. NONRESIDENT ALIEN. - A nonresident alien individual who, in association with others, derives gains and profits from the sale, within the United States, of merchandise manufactured without the United States is liable to the United States for income tax upon such gains and profits.

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1. NONRESIDENT ALIEN. - A nonresident alien individual who, in association with others, derives gains and profits from the sale, within the United States, of merchandise manufactured without the United States is liable to the United States for income tax upon such gains and profits. Richard L. Birkin,5 B.T.A. 402. 2. COST OF GOODS SOLD. - The respondent has accepted the books of account kept on behalf of the petitioner's decedent and his associates at their New York office as showing the cost of goods sold in the United States. Evidence offered on behalf of the petitioner held insufficient to…

1Opinion of the Court

CHARLES J. BILLWILLER, RESIDENT AGENT, ESTATE OF JOHN W. BILLWILLER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Billwiller v. Commissioner

Docket Nos. 8313, 8314.

United States Board of Tax Appeals

11 B.T.A. 841; 1928 BTA LEXIS 3710;

April 26, 1928, Promulgated

1. NONRESIDENT ALIEN. - A nonresident alien individual who, in association with others, derives gains and profits from the sale, within the United States, of merchandise manufactured without the United States is liable to the United States for income tax upon such gains and profits. Richard L. Birkin,5 B.T.A. 402.

2. COST OF…

2Cases cited2 opinions

  1. Birkin v. CommissionerUnited States Board of Tax Appeals · 1926
  2. Billwiller v. CommissionerUnited States Board of Tax Appeals · 1928

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