Adda v. COMMISSIONER OF INTERNAL REVENUE

PER CURIAM..This is a petition by a non-resident alien to review a decision of the Tax Court. Petitioner is a national of Egypt, who in the year 1941 was residing in France. He had a brother who at that time was residing in the United States and who traded for petitioner’s benefit on commodity exchanges in the United States in cotton, wool, grains, silk, hides and copper. This trading was authorized by petitioner who vested full discretion in his brother with regard thereto, and it resulted in profits in the sum of $193,857.14. The Tax Court said: “While the number of transactions or the…