BREWSTER v. C. I. R.

No. 71-1485.

473 F.2d 160 (1972)

Anne Moen Bullitt BREWSTER, Appellant, v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, District of Columbia Circuit.

Decided November 21, 1972.

Rehearing Denied January 23, 1973.


Attorney(s) appearing for the Case

Mr. Michael Mulroney, Washington, D. C., with whom Mr. Thomas E. Jenks, Washington, D. C., was on the brief, for appellant.

Mr. Loring W. Post, Atty., Tax Div., Dept. of Justice, for appellee.

Before LEVENTHAL, ROBINSON and ROBB, Circuit Judges.


PER CURIAM:

Taxpayer, a citizen of the United States, was a bona fide resident during the taxable years 1956-1960 of Ireland, where she engaged in the business of farming, raising cattle, and breeding, training and racing horses, in which both her personal services and capital were income-producing factors. She is therefore governed by Section 911 of the Internal Revenue Code of 1954, relating to earned income from sources without the United States.

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