Legal Opinion
Continental Trading, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided April 16, 1959No. 15912_1PublishedCited by 3 opinions
1Opinion of the Court
POPE, Circuit Judge.
Petitioner is a Panamanian corporation. It was organized in May, 1947, and maintained its principal office in Mexico City. For the year 1948 it filed an income tax return in California, and for the years 1949 and 1950 it filed such returns in Nevada.
The Commissioner determined deficiencies in the income tax of petitioner for each of those three years. The returns had been filed upon the assumption and with the claim that petitioner was a resident foreign corporation engaged in trade or business in the United States. The Commissioner determined, however, that it was a…
2Cases cited5 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Commissioner of Internal Revenue v. SmithCourt of Appeals for the Second Circuit · 1953
- Linen Thread Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1942
- Linen Thread Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
3Cited by3 opinions
- United Food and Commercial Workers Union v. Progressive SupermarketsDistrict Court, D. New Jersey · 1986
- Link v. CommissionerUnited States Tax Court · 1988
- Link v. CommissionerUnited States Tax Court · 1988