SWAN, Circuit Judge.
This is an action for the recovery of income taxes for the year 1943 paid to the defendant collector. The plaintiffs are British corporations not engaged in trade or business in the United States. Pursuant to a contract they had made with Samuel Goldwyn, Inc., a New York corporation, the latter paid them in London, England, $201,000 ($40,000 and £40,000) upon which a tax of 30%, subject to withholding at the source, was collected by virtue...
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