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TOOTAL BROADHURST LEE CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 97.

30 F.2d 239 (1929)

TOOTAL BROADHURST LEE CO., Limited, v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

January 7, 1929.

Attorney(s) appearing for the Case

Satterlee & Canfield, of New York City (F. Morse Hubbard and Lloyd F. Thanhouser, both of New York City, of counsel), for petitioner.

Mabel Walker Willebrandt, Asst. Atty. Gen., Sewall Key and Morton P. Fisher, Sp. Asst. Attys. Gen. (C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and Thomas P. Dudley, Jr., Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., of counsel), for respondent.

Before MANTON, L. HAND, and AUGUSTUS N. HAND, Circuit Judges.

MANTON, Circuit Judge.

The petitioner, a British corporation having an office in New York City, manufactured in England cotton goods which it sold in the United States. During the fiscal year ending June 30, 1920, there was derived from such merchandise, so manufactured and sold, income amounting to $246,168.71. The question presented by this petition is whether the income derived by this foreign corporation from sales in the United States of this merchandise is income...

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