SWENSON v. THOMAS

No. 11923.

164 F.2d 783 (1947)

SWENSON v. THOMAS.

Circuit Court of Appeals, Fifth Circuit.

December 4, 1947.


Attorney(s) appearing for the Case

John S. Carlson and Joseph L. Hull, Jr., both of Tulsa, Okl., and J. P. Jackson and S. G. Sinstead, both of Dallas, Tex., for appellant.

Lester L. Gibson and Sewall Key, Sp. Assts. to Atty. Gen., and William P. Fonville, Asst. U. S. Atty., of Dallas, Tex., for appellee.

Before SIBLEY, HOLMES, and McCORD, Circuit Judges.


SIBLEY, Circuit Judge.

Appellant Swenson paid assessed deficiencies in income taxes for the years 1943 and 1944, and his claims for refund, based on his contention that salaries earned by working in Colombia, South America, during the whole of those years, was not taxable under Section 116(a) of the Internal Revenue Code, 26 U.S.C.A. Int.Rev.Code, § 116 (a), were neglected for six months and he brought suit against the representative of the Collector. The district...

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