GRECIAN MAGNESITE MINING v. COMM'R OF I.R.S.

No. 17-1268.

926 F.3d 819 (2019)

GRECIAN MAGNESITE MINING, INDUSTRIAL & SHIPPING CO., SA, Appellee v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Appellant.

United States Court of Appeals, District of Columbia Circuit.

Decided June 11, 2019.


Attorney(s) appearing for the Case

Deborah K. Snyder , Attorney, U.S. Department of Justice, argued the cause for appellant. With her on the briefs were Travis A. Greaves , Deputy Assistant Attorney General, and Gilbert S. Rothenberg and Richard Farber , Attorneys.

Michael J. Miller argued the cause for appellee. With him on the brief was Ellen Brody .

Before: Rogers and Srinivasan, Circuit Judges, and Ginsburg, Senior Circuit Judge.


Grecian Magnesite Mining, a foreign corporation, realized substantial income when it redeemed its interest in a U.S. partnership. At the time, Grecian operated entirely outside the United States, save for its interest in the partnership. The question we face is whether the geographic...

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