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LEWENHAUPT v. COMMISSIONER OF INTERNAL REVENUE

No. 14069.

221 F.2d 227 (1955)

Jan Casimir LEWENHAUPT, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Ninth Circuit.

Rehearing Denied May 16, 1955.

Attorney(s) appearing for the Case

Samuel Taylor, Walter G. Schwartz, San Francisco, Cal., for petitioner.

H. Brian Holland, Asst. Atty. Gen., Louise Foster, Ellis N. Slack, Howard P. Locke, Walter Akerman, Jr., Sp. Assts. to Atty. Gen., Kenneth W. Gemmill, Acting Chief Counsel, Internal Revenue Service, Washington, D. C., for respondent.

Before HEALY and BONE, Circuit Judges, and CLARK, District Judge.

PER CURIAM.

This case, here on petition for review of a decision of the Tax Court, involves the interpretation of Articles V and IX of the tax convention between the United States and Sweden, and the validity of section 25.6 of the Commissioner's regulations.

The petitioner, a citizen and resident of Sweden, in 1946 sold real property situated in the United States, realizing gain from the sale thereof. The Tax Court sustained a ruling of the Commissioner holding...

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