Jules SAMANN, Petitioner,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent.
United States Court of Appeals Fourth Circuit.https://leagle.com/images/logo.png
Argued September 28, 1962.
Decided January 16, 1963.
Attorney(s) appearing for the Case
Karl Riemer, Washington, D. C. (Pehle, Mann, Riemer & Luxford, Washington, D. C., on brief), for petitioner.
John B. Jones, Jr., Attorney, Department of Justice (Louis F. Oberdorfer, Asst. Atty. Gen., Meyer Rothwacks, Harry Baum, and Harold C. Wilkenfeld, Attorneys, Department of Justice, on brief), for respondent.
Before BRYAN and BELL, Circuit Judges, and JOHN PAUL, District Judge.
United States Court of Appeals Fourth Circuit.
ALBERT V. BRYAN, Circuit Judge.
The Income Tax Convention1 of 1951 between the United States and Switzerland exempts from Federal taxation royalties derived from sources in the United States by a Swiss resident "not having a permanent establishment" in this country. By Treasury regulation2 the condition of no permanent establishment written into the exemption is declared to require that there be no such establishment...
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