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HELVERING v. SUFFOLK CO.

No. 4451.

104 F.2d 505 (1939)

HELVERING, Com'r of Internal Revenue, v. SUFFOLK CO., Limited.

Circuit Court of Appeals, Fourth Circuit.

June 12, 1939.

Attorney(s) appearing for the Case

L. W. Post, Sp. Asst. to Atty. Gen. (James W. Morris, Asst. Atty. Gen., and Sewall Key, Sp. Asst. to Atty. Gen., on the brief), for petitioner.

Richard H. Wilmer, of Washington, D. C. (Thomas F. Boyle, William D. Whitney, and Joseph C. White, all of New York City, on the brief), for respondent.

Before PARKER, NORTHCOTT, and SOPER, Circuit Judges.

SOPER, Circuit Judge.

This petition for review requires an interpretation of section 119 of the Revenue Act of 1932, 47 Stat. 169, 208, 26 U. S.C.A. § 119, relating to income from sources within and sources without the United States, so that the taxable income of the Suffolk Company, Ltd., a corporation organized under the laws of Newfoundland, from sources within the United States in the tax year of 1933 may be determined.

On February 19, 1932, pursuant...

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