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INGRAM v. BOWERS

47 F.2d 925 (1931)

INGRAM v. BOWERS.

District Court, S. D. New York.

February 9, 1931.

Attorney(s) appearing for the Case

Wise, Whitney & Parker, of New York City (Francis C. Lowthorp and James A. Dilkes, both of New York City, of counsel), for plaintiff.

Robert E. Manley, Acting U. S. Atty., of New York City (Walter H. Schulman, of New York City, of counsel), for defendant.

PATTERSON, District Judge.

Action at law is brought to recover additional income taxes for the years 1918, 1919, and 1920, paid under protest by the plaintiff as ancillary administratrix of Enrico Caruso, deceased. By stipulation the case was tried before a jury of one and both sides moved for a directed verdict.

The case concerns the taxability of income received by Caruso by reason of the sale of phonograph records outside the United States, it being conceded...

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