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MOLNAR v. COMMISSIONER OF INTERNAL REVENUE

No. 249, Docket 20158.

156 F.2d 924 (1946)

MOLNAR v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

June 24, 1946.

Attorney(s) appearing for the Case

John J. Sweedler, of New York City, for petitioner Ferenc (Franz) Molnar.

Sewall Key, Acting Asst. Atty. Gen., and J. Louis Monarch and Norman S. Altman, Sp. Assts. to Atty. Gen., for respondent Commissioner of Internal Revenue.

Before L. HAND, AUGUSTUS N. HAND and CLARK, Circuit Judges.

AUGUSTUS N. HAND, Circuit Judge.

The question presented by the petition to review the order of the Tax Court determining a deficiency of $3,684.71 in the income tax of the taxpayer Molnar for the year 1941 is whether the latter has established that any part of the lump-sum payments he received from American motion pictures producers for his world motion picture rights constituted income from sources outside of the United States within the meaning of Sections 119 and...

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