Ronrico Corp. v. Commissioner
United States Board of Tax Appeals
Petitioner, a Puerto Rican corporation engaged in the manufacture of rum, in the taxable year 1935 entered into an exclusive marketing agreement with a New York distributor under which it sold 66 shipments of rum. Held, gross income from such sales did not arise within the United States but in Puerto Rico, where the sales were completed.
1Opinion of the Court
*1133OPINION.
ARUNdeul :
The parties have agreed that $19,660.94 preproduction expenses claimed as a deduction by petitioner are not deductible, and that “other expenses” of $2,095.25 and directors’ compensation of *1134$8,309 claimed by petitioner as deductions are deductible. In the event our decision is that petitioner received income from sources within the United States, these two last named expenses are to be allocated in accordance with the allocation made in the deficiency notice herein.
The principal issue in this case is whether the petitioner, a foreign corporation, had gross income from…
2Cases cited10 opinions
- Myers v. Hurley Motor Co.Supreme Court of the United States · 1927
- Compañia General De Tabacos De Filipinas v. Collector of Internal RevenueSupreme Court of the United States · 1929
- Seaver v. . Lindsay Light Co.New York Court of Appeals · 1922
- Mee v. . McNiderNew York Court of Appeals · 1888
- Harper v. HochstimCourt of Appeals for the Second Circuit · 1921
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3Cited by12 opinions
- A. P. Green Export Company v. United StatesUnited States Court of Claims · 1960
- United States v. BalanovskiCourt of Appeals for the Second Circuit · 1956
- Barber-Greene Americas, Inc. v. CommissionerUnited States Tax Court · 1960
- United States v. BalanovskiCourt of Appeals for the Second Circuit · 1956
- Hermanos v. Tribunal de Contribuciones de Puerto RicoSupreme Court of Puerto Rico · 1946
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