Legal Opinion
Corporacion De Ventas De Salitre Y Yoda De Chile v. Commissioner
Court of Appeals for the Second Circuit
Decided July 17, 1942No. 115PublishedCited by 8 opinions
1Opinion of the Court
SWAN, Circuit Judge.
The question presented is whether a Chilean corporation realized taxable income by purchasing in the United States some of its own debenture bonds at less than their face value. The taxpayer contends, first, that the unusual circumstances under which its debentures were issued, and the limitations upon liability which they contained precluded its realization of gain by their purchase; second, that if gain was realized, it was not “income from sources within the United States,” which alone is taxable under section 231 of the *142Revenue Act of 1934, 26 U.S.C.A. Int.Rev. Acts,…
2Cases cited5 opinions
- Higgins v. SmithSupreme Court of the United States · 1940
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Helvering v. American Chicle Co.Supreme Court of the United States · 1934
- Commissioner of Internal Revenue v. Rail Joint Co.Court of Appeals for the Second Circuit · 1932
- Commissioner of Int. Rev. v. Coastwise Transp. Corp.Court of Appeals for the First Circuit · 1934
3Cited by8 opinions
- Fifth Avenue-Fourteenth Street Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
- Kronenberg v. CommissionerUnited States Tax Court · 1975
- State v. Gulf Oil CorporationCourt of Civil Appeals of Alabama · 1971
- Central Paper Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1946
- Gulf-Puerto Rico Lines, Inc. v. CommissionerUnited States Tax Court · 1974
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