WODEHOUSE v. COMMISSIONER OF INTERNAL REVENUE

Docket 3, No. 20925.

177 F.2d 881 (1949)

WODEHOUSE v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Second Circuit.

Decided November 21, 1949.


Attorney(s) appearing for the Case

Watson Washburn, New York City, for petitioner; Royal E. Mygatt, New York City, of counsel.

Charles Oliphant, Washington, D. C., Theron Lamar Caudle, Assistant Attorney General, Ellis N. Slack and Helen Goodner, Special Assistants to the Attorney General, for respondent.

Before L. HAND, SWAN, and CLARK, Circuit Judges.


SWAN, Circuit Judge.

This appeal involves the 1940 income tax of the well-known author P. G. Wodehouse. He is a non-resident alien. During the year 1940 he received income from sources within the United States taxable under section 211 of the Internal Revenue Code, 26 U.S.C.A. § 211. The appeal does not question his taxability, but challenges the amount of the deficiency found against him.

The facts giving rise to the questions presented may be stated...

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