González Díaz v. Descartes

The problem for our consideration is limited to determining whether under our Income Tax Act the profit made by a nonresident foreigner in the sale of his share in a *865commercial partnership domiciled in this island is taxable in Puerto Rico.

Plaintiff, Juana González Díaz, is the sole and universal heir of María Diaz Miyares widow of Abarca, who died in Spain in 1947. Her ancestor was a limited partner of the partnership Sucesores de Abarca, Ltd., organized and domiciled in Puerto Rico where its commercial activities developed. By public deed of December 30, 1940 Enrique Abarca Sanfeliz, as…