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COMM'R v. SCOTTISH AMERICAN CO.

No. 52.

323 U.S. 119 (1944)

65 S.Ct. 169

89 L.Ed. 113

COMMISSIONER OF INTERNAL REVENUE v. SCOTTISH AMERICAN INVESTMENT CO., LTD.

Supreme Court of United States.

Decided December 4, 1944.

Attorney(s) appearing for the Case

Mr. J. Louis Monarch, with whom Solicitor General Fahy, Assistant Attorney General Samuel O. Clark, Jr., Mr. Sewall Key, and Miss Helen Goodner were on the brief, for the Commissioner of Internal Revenue.

Mr. Marion N. Fisher, with whom Mr. George Craven was on the brief, for the taxpayers.

MR. JUSTICE MURPHY delivered the opinion of the Court.

We are confronted here with another aspect of the problem of the judicial reviewability of Tax Court determinations.

The three taxpayers involved in these cases are investment trusts organized under the laws of Great Britain, with principal offices in Edinburgh, Scotland. Each is engaged in the business of investing the funds of its security holders for the primary purpose of deriving income from investments...

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