COMMISSIONER OF INTERNAL REVENUE v. NUBAR

No. 6145.

185 F.2d 584 (1950)

COMMISSIONER OF INTERNAL REVENUE v. NUBAR.

United States Court of Appeals Fourth Circuit.

Decided November 8, 1950.

Rehearing Denied December 20, 1950.


Attorney(s) appearing for the Case

Irving I. Axelrad, Sp. Asst. to Atty. Gen. (Theron Lamar Caudle, Asst. Atty. Gen., Ellis N. Slack and Helen Goodner, Sp. Assts. to Atty. Gen., on the brief), for petitioner.

Henry Mannix and Charles K. Rice, New York City, for respondent.

Before PARKER, Chief Judge, and SOPER and DOBIE, Circuit Judges.


PARKER, Chief Judge.

This is an appeal from a decision of the Tax Court involving deficiencies of $318,220.26 in income taxes assessed for the years 1941, 1943 and 1944 against a citizen of Egypt who had been in this country from 1939 to 1945 and who had made profits of exceeding $600,000 during the years in question by trading on the exchanges of the country in stocks and commodities. Taxpayer contended that he was a non-resident alien not engaged in a trade or business...

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