Muhleman v. Hoey

CHASE, Circuit Judge.

The plaintiffs, as executors of the last will of Arthur C. Mower, brought this suit in the Southern District of New York to recover the income taxes which he had paid on $310,706.24 that he received in 1932 by way of a bonus in addition to his regular salary for services performed abroad in 1931.

This amount was paid to him in this country by the American Tobacco Company during 1932 for his services performed in 1931, while a resident of London, Eng., as the manager of its foreign subsidiaries. He reported his income on the cash basis for the calendar year 1932 but did not…