Legal Opinion
Linen Thread Co. v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided December 28, 1945No. 54PublishedCited by 6 opinions
1Opinion of the Court
SWAN, Circuit Judge.
This litigation results from disagreement between the parties as to whether the taxpayer, incorporated under the laws of Scotland, is taxable on income received from sources within the United States during the years 1939 and 1940, as a nonresident un*626der paragraph (a) of section 231 of the Internal Revenue Code, 26 U.S.C.A. Int. Rev.Code, § 231 (a, b), or as a resident under paragraph (b) of said section. The commissioner taxed it as a nonresident corporation and the Tax Court sustained his ruling; the petitioner contends this was error.
The same dispute with respect to the…
2Cases cited4 opinions
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Commissioner v. Scottish American Investment Co.Supreme Court of the United States · 1945
- Commissioner v. RabenoldCourt of Appeals for the Second Circuit · 1940
- Linen Thread Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1942
3Cited by6 opinions
- Fairmont Aluminum Co. v. CommissionerUnited States Tax Court · 1954
- Maguire v. CommissionerUnited States Tax Court · 1968
- Robert Y. H. Thomas and Mary B. Thomas v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1963
- Continental Trading, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
- Fairmont Aluminum Co. v. CommissionerUnited States Tax Court · 1954
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