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RAWAT v. C.I.R.

No. 23-1142.

108 F.4th 891 (2024)

Indu RAWAT, Appellant v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided July 23, 2024.

Attorney(s) appearing for the Case

Christopher S. Rizek argued the cause for appellant. With him on the briefs were Leila D. Carney and Nathan J. Hochman.

Douglas C. Rennie, Attorney, U.S. Department of Justice, argued the cause for appellee. With him on the brief was Jacob Earl Christensen, Attorney.

Before: Srinivasan, Chief Judge, Millett and Walker, Circuit Judges.

In 2008, Indu Rawat, a foreign businesswoman, sold her partnership stake in a U.S. company for $438 million. Approximately $6.5 million of that sum was attributable to a gain on the company's inventory. The question in this case is whether that inventory gain is U.S.-source income subject to U.S. taxes. We hold it is not...

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