Legal Opinion
Commissioner v. Scottish American Inv. Co.
Court of Appeals for the Third Circuit
Decided April 6, 1944No. Nos. 8337, 8338, 8339PublishedCited by 1 opinion
1Opinion of the Court
McLaughlin, circuit judge.
These are companion cases and were argued together. The respondent companies are British corporations. The question is : Whether they were engaged in trade or business or had an office or place of business within the United States in the taxable years 1938 and 1939 so as to qualify within the meaning of Section 231(b) of the Revenue Act of 1938 and of the Internal Revenue Code, 26 U.S.C.A. Int.Rev. Code, § 231(b), as resident foreign corporations. The section reads:
“(b) Resident corporations.—A foreign corporation engaged in trade or business within the United States…
2Cases cited5 opinions
- Dobson v. CommissionerSupreme Court of the United States · 1944
- BW Jones Trust v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1943
- Linen Thread Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1942
- Aktiebolaget Separator v. CommissionerUnited States Board of Tax Appeals · 1941
- Connell v. WalkerSupreme Court of the United States · 1933
3Cited by1 opinion
- Commissioner v. Scottish American Investment Co.Supreme Court of the United States · 1945