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BEAUMONT v. HELVERING

No. 5870.

73 F.2d 110 (1934)

BEAUMONT v. HELVERING, Commissioner of Internal Revenue.

United States Court of Appeals for the District of Columbia.

Rehearing Denied October 12, 1934.

Attorney(s) appearing for the Case

James Craig Peacock, Claude E. Koss, and John W. Townsend, all of Washington, D. C., for petitioner.

E. Barrett Prettyman, Thomas M. Mather, Helen R. Carloss, G. A. Youngquist, Sewall Key, and C. M. Charest, all of Washington, D. C., for respondent.

Before MARTIN, Chief Justice, and ROBB, HITZ, and GRONER, Associate Justices.

HITZ, Associate Justice.

This is an appeal from a decision of the Board of Tax Appeals, and while a number of questions were argued there, only two are in issue here. These items relate to the petitioner's returns for the years 1925, 1926, 1927, 1928, and the questions are:

(1) Do certain sums received by the petitioner from American corporations while he was residing abroad constitute compensation for services rendered by him without the United States, and...

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