Legal Opinion

Tootal Broadhurst Lee Co. v. Commissioner

United States Board of Tax Appeals

Decided November 25, 1927No. Docket No. 15962Published

When goods are manufactured abroad by a foreign corporation and sold in this country, the entire profit constitutes "gross income from sources within the United States," within the meaning of section 233(b) of the Revenue Act of 1918.

1Opinion of the Court

TOOTAL BROADHURST LEE CO., LTD., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Tootal Broadhurst Lee Co. v. Commissioner

Docket No. 15962.

United States Board of Tax Appeals

9 B.T.A. 321; 1927 BTA LEXIS 2616;

November 25, 1927, Promulgated

When goods are manufactured abroad by a foreign corporation and sold in this country, the entire profit constitutes "gross income from sources within the United States," within the meaning of section 233(b) of the Revenue Act of 1918.

F. Morse Hubbard, Esq., for the petitioner.

Henry Ravenel, Esq., for the respondent.

LITTLETON

The Commissioner…

2Cases cited1 opinion

  1. Tootal Broadhurst Lee Co. v. CommissionerUnited States Board of Tax Appeals · 1927

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