No. 90-1231.

936 F.2d 1316 (1991)


United States Court of Appeals, District of Columbia Circuit.

Decided June 28, 1991.

Attorney(s) appearing for the Case

William E. Halmkin, Boston, Mass., for appellant.

Bridget M. Rowan, Atty., Dept. of Justice, with whom Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen, and Robert S. Pomerance, Attys., Dept. of Justice, were on the brief, for appellee.

John A. Dudeck, Jr., Atty., Dept. of Justice, also entered an appearance, Washington, D.C., for appellee.

Before SILBERMAN, BUCKLEY and HENDERSON, Circuit Judges.

Opinion for the court filed by Circuit Judge BUCKLEY.

BUCKLEY, Circuit Judge:

We are asked to determine whether the United States-Canada Income Tax Convention of 1942 permits the United States to tax a Canadian resident's distributable share of capital gain realized by a Massachusetts partnership in which he is a limited partner. On the settled authority of Donroy, Ltd. v. United States, 301 F.2d 200 (9th Cir.1962)...

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