BANK OF AMERICA v. UNITED STATES

No. 402-71.

680 F.2d 142 (1982)

BANK OF AMERICA, an Edge Act corporation, v. The UNITED STATES.

United States Court of Claims.

June 2, 1982.


Attorney(s) appearing for the Case

Stephen J. Swift, San Francisco, Cal., atty. of record, for plaintiff; Charles R. Conradi, San Francisco, Cal., of counsel.

Kenneth R. Boiarsky, with whom was Asst. Atty. Gen. Glenn L. Archer, Jr., Washington, D. C., for defendant; Theodore D. Peyser and Donald H. Olson, Washington, D. C., of counsel.

Before DAVIS, KASHIWA and SMITH, Judges.


OPINION

KASHIWA, Judge:

This case is before the court on the defendant's exceptions to the findings of fact and recommended opinion of Trial Judge John P. Wiese. We are faced with the question whether certain commissions received by the plaintiff, Bank of America, an Edge Act corporation, should be characterized as United States or foreign source income for purposes of the Internal Revenue Code. The trial judge held that all the commissions at issue should...

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