Legal Opinion
Thomas Browne Foster v. United States
Court of Appeals for the Second Circuit
Decided March 31, 1964No. 28533_1PublishedCited by 19 opinions
1Opinion of the Court
MARSHALL, Circuit Judge:
In this suit for refund of income taxes paid for the years 1953 and 1954, taxpayer appeals from a judgment for the Government entered after trial without jury. It will be seen from an examination of Judge Levet’s opinion below, 221 F.Supp. 291, that the principal issue on the trial was whether appellant’s monthly drawing account, which he received while in Saudi Arabia as a partner in the firm of Emerson Engineers, was a salary, therefore “[e]arned income from sources without the United States” within the meaning of sections 116(a) of the Internal Revenue Code of 1939…
2Cases cited11 opinions
- Neuberger v. CommissionerSupreme Court of the United States · 1940
- Commissioner of Internal Revenue v. LehmanCourt of Appeals for the Second Circuit · 1948
- Jennings v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1940
- Benjamin v. HoeyCourt of Appeals for the Second Circuit · 1944
- Craik v. United StatesUnited States Court of Claims · 1940
6 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Empire Life Insurance Company of America v. Valdak CorporationCourt of Appeals for the Fifth Circuit · 1972
- Telco Leasing, Inc. v. Transwestern Title Co., D/B/A California Land Title Co. Of MarinCourt of Appeals for the Ninth Circuit · 1980
- Vintero Corporation v. Corporacion Venezolana De FomentoCourt of Appeals for the Second Circuit · 1982
- American Surety Company of New York v. Ralph E. Coblentz, as Administrator D.B.N. Of the Estate of Edward Thomas Coblentz, DeceasedCourt of Appeals for the Fifth Circuit · 1967
- Miller v. CommissionerUnited States Tax Court · 1969
14 more not listed; retrieve them via the Exa API.