Molnar v. Commissioner of Internal Revenue

AUGUSTUS N. HAND, Circuit Judge.

The question presented by the petition to review the order of the Tax Court determining a deficiency of $3,684.71 in the income tax of the taxpayer Molnar for the year 1941 is whether the latter has established that any part of the lump-sum payments he received from American motion pictures producers for his world .motion picture rights constituted income from sources outside of the United States within the meaning of Sections 119 and 212 of the Internal Revenue Code.1

On April 17, 1941 the taxpayer, a citizen *925of Hungary, entered into a written contract in New…