Seeley v. Commissioner of Internal Revenue. Seeley v. Commissioner of Internal Revenue

L. HAND, Chief Judge.

The taxpayers — in one proceeding, a husband and wife, in the other, the husband alone — petition to review assessments against them upon their income taxes for the years 1943 and 1944; we shall disregard the wife and speak as though the husband alone were concerned. The question is of his gross income in the years in question: in particular, whether there should be included in it sums which he ■earned for services performed outside the United States. In short, the question is whether as to these amounts he brought himself within § 116(a) of the Internal Revenue Code. 1…