Legal Opinion
Around the World Shoppers Club v. United States
Court of Appeals for the Third Circuit
Decided November 9, 1962No. 13895PublishedCited by 6 opinions
1Per curiam
The issue dispositive of this appeal is whether certain sales made by the appellant to its members took place within the United States. The parties agree that if this is so, appellant is subject to the Retailers Excise Taxes imposed by the Internal Revenue Code of 1954, §§ 400Í-4058, 26 U.S.C.A. §§ 4001-4058.
Based on a stipulation of facts, the district court concluded that the sales occurred in this country. Of course, since this conclusion constitutes an ultimate finding of fact, it is subject to review free of the restraint of the “clearly erroneous” rule applicable to ordinary findings of…
2Cases cited4 opinions
- Philber Equipment Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1956
- The Pennroad Corporation and Affiliated Companies v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Joseph B. And Josephine L. Simon v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Joseph B. And Josephine L. SimonCourt of Appeals for the Third Circuit · 1961
- George K. Heebner, Jr. And Ruth S. Heebner v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1960
3Cited by6 opinions
- Estate of Maria M. Coxe Skinner, Deceased, Neil McFee Skinner and Girard Trust Corn Exchange Bank, Executors v. United StatesCourt of Appeals for the Third Circuit · 1963
- Pflugradt v. United StatesCourt of Appeals for the Seventh Circuit · 1962
- Williamson v. Compania Anonima Venezolana de NavigacionCourt of Appeals for the Second Circuit · 1971
- Overseas Mailman, Inc. v. United StatesDistrict Court, D. New Jersey · 1971
- Allen Pflugradt and Ethel Pflugradt, His Wife v. United States of America, John Roggenbauer Moeller v. United States of America, James W. Pflugradt and Lillian Pflugradt, His Wife v. United States of America, Jane Wolfe v. United StatesCourt of Appeals for the Seventh Circuit · 1962
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