This case involves deficiencies in income tax of $9,747.24 and $24,743.95 for the years 1940 and 1941, respectively.
The primary issue presented is, whether the petitioner, a foreign corporation, is a nonresident corporation taxable under section 231 (a) of the Internal Revenue Code, or was engaged in trade or business within the United States within the meaning of section 231 (b) so as to be taxable under section 14 (c) (1).
The petitioner contends that,...
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