Stein v. Commissioner
United States Board of Tax Appeals
1. INCOME - SOURCES WITHIN UNITED STATES - FOREIGN BILLS OF EXCHANGE. - Transactions of a foreign banking partnership, whereby it caused drafts drawn to its order by clients abroad to be accepted by banks in the United States solely on its own credit and with the understanding that it would cover them two days before maturity, discounted the accepted drafts in the United States, and, after acceptance of drafts, made advances to clients and collected the amount of the drafts…
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1. INCOME - SOURCES WITHIN UNITED STATES - FOREIGN BILLS OF EXCHANGE. - Transactions of a foreign banking partnership, whereby it caused drafts drawn to its order by clients abroad to be accepted by banks in the United States solely on its own credit and with the understanding that it would cover them two days before maturity, discounted the accepted drafts in the United States, and, after acceptance of drafts, made advances to clients and collected the amount of the drafts from them when they became payable, held not to involve a purchase of personal property without the United States,…
1Opinion of the Court
*852OPlNtON.
Mukdock :
The first question for decision is whether Straus & Co. had any gross income from sources within the United States within the meaning of section 119 (e) of the Revenue Act of 1928. The only contention made by the Commissioner is that the transactions which the partnership had in drafts drawn on banks in the United States represented “gains, profits and income * * * from the purchase of personal property without and its sale within the United States.” Section 119 (e) of the Revenue Act of 1928, upon which he relies, provides that such gains, profits, and income shall be…
2Cases cited10 opinions
- Fairbanks v. United StatesSupreme Court of the United States · 1939
- City of Douglas v. Federal Reserve Bank of DallasSupreme Court of the United States · 1926
- Schermerhorn v. . TalmanNew York Court of Appeals · 1856
- Haddock, Blanchard Co. v. . HaddockNew York Court of Appeals · 1908
- Heinrich v. First National BankNew York Court of Appeals · 1916
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3Cited by5 opinions
- Capital One Financial Corp. v. CommissionerCourt of Appeals for the Fourth Circuit · 2011
- Hunt v. CommissionerUnited States Tax Court · 1988
- Capital One Financial Corporation v. CommissionerCourt of Appeals for the Fourth Circuit · 2011
- Hunt v. CommissionerUnited States Tax Court · 1988
- Stein v. CommissionerUnited States Board of Tax Appeals · 1939