Legal Opinion
Tootal Broadhurst Lee Co. v. Commissioner
Court of Appeals for the Second Circuit
Decided January 7, 1929No. 97PublishedCited by 3 opinions
1Opinion of the Court
MANTON, Circuit Judge.
The petitioner, a British corporation having an office in New York City, manufactured in England cotton goods which it sold in the United States. During the fiscal year ending June 30, 1920, there was derived from such merchandise, so manufactured and sold, income amounting to $246,168.71. The question presented by this petition is whether the income derived by this foreign corporation from sales in the United States of this merchandise is income from sources within the United States under section 233(b) of the Revenue Act of 1918 (40 Stat. 1077), which provides that “in…
2Cases cited5 opinions
- Eisner, Internal Revenue Collector v. MacOmberSupreme Court of the United States · 1919
- Lynch v. HornbySupreme Court of the United States · 1918
- Barclay & Co. v. EdwardsSupreme Court of the United States · 1925
- National Paper & Type Co. v. BowersSupreme Court of the United States · 1924
- United States v. WeissmanSupreme Court of the United States · 1924
3Cited by3 opinions
- Eastman Kodak Co. v. District of ColumbiaDistrict Court, District of Columbia · 1942
- Gross Income Tax Division v. BartlettIndiana Supreme Court · 1950
- Billwiller's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1929