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C. V. STARR & CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 4425.

101 F.2d 611 (1939)

C. V. STARR & CO., Federal Inc. U. S. A., v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fourth Circuit.

February 3, 1939.

Attorney(s) appearing for the Case

L. C. Collins, of Washington, D. C., and J. B. Allman, of Rockymount, Va., for petitioner.

Lee A. Jackson, Sp. Asst. to Atty. Gen. (James W. Morris, Asst. Atty. Gen., and Sewall Key, Sp. Asst. to Atty. Gen., on the brief), for respondent.

Before PARKER and SOPER, Circuit Judges, and CHESNUT, District Judge.

SOPER, Circuit Judge.

The Revenue Act of 1932, c. 209, section 261 (a), 47 Stat. 169, 26 U.S.C.A. § 261 (a) provides, for the purpose of the income tax imposed by section 13 thereof, 26 U.S.C.A. § 13, that in the case of a corporation organized under the China Trade Act of 1922, c. 346, 42 Stat. 849, 15 U.S.C.A. § 141 et seq., a credit against the net income shall be allowed, based upon the net income derived from sources within China; provided that...

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