Legal Opinion
Misbourne Pictures Limited v. Johnson
Court of Appeals for the Second Circuit
Decided June 11, 1951No. 22013_1PublishedCited by 23 opinions
1Opinion of the Court
SWAN, Circuit Judge.
This is an action for the recovery of income taxes for the year 1943 paid to the defendant collector. The plaintiffs are British corporations not engaged in trade or business in the United States. Pursuant to a contract they had made with Samuel Goldwyn, Inc., a New York corporation, the latter paid them in London, England, $201,000 ($40,000 and £40,000) upon which a tax of 30%, subject to withholding at the source, was collected by virtue of sections 231(a) (1) and 144 of the Internal Revenue Code. A claim for refund thereof having been filed and no action taken thereon,…
2Cases cited10 opinions
- Commissioner of Internal Revenue v. Celanese Corp.Court of Appeals for the D.C. Circuit · 1944
- Rohmer v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1946
- Commissioner v. WodehouseSupreme Court of the United States · 1949
- Goldsmith v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1944
- Sabatini v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1938
5 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Leahy v. CommissionerUnited States Tax Court · 1986
- Tolwinsky v. CommissionerUnited States Tax Court · 1986
- Durkin v. CommissionerUnited States Tax Court · 1986
- Daniel M. Cory and Margot Cory, His Wife, Petitioners-On-Review v. Commissioner of Internal Revenue, Respondent-On-ReviewCourt of Appeals for the Second Circuit · 1956
- Cory v. CommissionerUnited States Tax Court · 1955
18 more not listed; retrieve them via the Exa API.