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UNITED STATES v. STUART

No. 87-1064.

489 U.S. 353 (1989)

UNITED STATES v. STUART ET AL.

Supreme Court of United States.

Decided February 28, 1989

Attorney(s) appearing for the Case

Deputy Solicitor General Wallace argued the cause for the United States. With him on the briefs were Solicitor General Fried, Assistant Attorney General Rose, Alan I. Horowitz, Charles E. Brookhart, and John A. Dudeck, Jr.

Charles E. Peery argued the cause for respondents. On the brief was Brian L. McEachron.

JUSTICE BRENNAN delivered the opinion of the Court.

Articles XIX and XXI of the Convention between the United States and Canada Respecting Double Taxation, Mar. 4, 1942, 56 Stat. 1405-1406, T. S. No. 983, oblige the United States, upon request and consistent with United States revenue laws, to obtain and convey information to Canadian authorities to assist them in determining a Canadian taxpayer's income tax liability. The question presented is whether the United...

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