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CINELLI v. C. I. R.

No. 74-1090.

502 F.2d 695 (1974)

Ferdinand CINELLI and Sarah M. Cinelli, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided September 5, 1974.

Attorney(s) appearing for the Case

William P. Thorpe, Detroit, Mich., for petitioners-appellants; McClintock, Donovan, Carson & Roach, Detroit, Mich., on briefs.

Harold J. Tulley, Tax Div., Dept. of Justice, Washington, D. C., for respondent-appellee; Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks, Grant W. Wiprud, Attys., Tax Div. Dept. of Justice, Washington, D. C., on briefs.

Before PHILLIPS, Chief Judge, and CELEBREZZE and ENGEL, Circuit Judges.

CELEBREZZE, Circuit Judge.

This case presents a single question of substantial significance to international commerce and United States taxation of its citizens' foreign income. That question is the proper means of giving foreign currency a United States dollar value when a foreign government's official rate of monetary exchange differs from the "free market" or "commercial" rate. Specifically, the issue is the proper measure of U.S. dollar value of real property...

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