Legal Opinion

Ingram v. Bowers

District Court, S.D. New York

Decided February 9, 1931PublishedCited by 15 opinions

1Opinion of the Court

PATTERSON, District Judge.

Action at law is brought to recover additional income taxes for the years 1918, 1919, and 1920, paid under protest by the plaintiff as ancillary administratrix of Enrico Caruso, deceased. By stipulation the case was tried before a jury of one and both sides moved for a directed verdict.

The case concerns the taxability of income received by Caruso by reason of the sale of phonograph records outside the United States, it being conceded that the singing by Caruso for the manufacture of such records occurred within the United States. The plaintiff contends: First, that…

2Cases cited5 opinions

  1. Woods v. LewellynCourt of Appeals for the Third Circuit · 1918
  2. Edwards v. KeithCourt of Appeals for the Second Circuit · 1916
  3. Bowring v. BowersCourt of Appeals for the Second Circuit · 1928
  4. Zimbalist v. AndersonDistrict Court, S.D. New York · 1928
  5. Zimbalist v. AndersonCourt of Appeals for the Second Circuit · 1930

3Cited by15 opinions

  1. Dillin v. CommissionerUnited States Tax Court · 1971
  2. Perkins v. CommissionerUnited States Tax Court · 1963
  3. Beaumont v. HelveringCourt of Appeals for the D.C. Circuit · 1934
  4. Tobey v. Comm'rUnited States Tax Court · 1973
  5. Ingram v. BowersCourt of Appeals for the Second Circuit · 1932

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