All Russian Textile Syndicate, Inc. v. Commissioner

CHASE, Circuit Judge.

The petitioner, a New York corporation with its principal place of business in New York City, acted as the purchasing agent for a Russian organization whose identity remains undisclosed. It made purchases in this country of goods as desired, cotton being the main commodity, and shipped them to its principal in Russia. The arrangement under which this was done is somewhat vaguely outlined, but enough appears to show that the Russian principal was to reimburse the petitioner for the purchase price of the goods' and for all expenses it incurred in buying the goods and…