SANCHEZ v. COMMISSIONER OF INTERNAL REVENUE

No. 208, Docket 20382.

162 F.2d 58 (1947)

SANCHEZ v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

June 21, 1947.


Attorney(s) appearing for the Case

Harry L. Gutter, of New York City (Arnold H. Shaw, of New York City, of counsel), for petitioner.

Sewall Key, Acting Asst. Atty. Gen., and Lee A. Jackson and Hilbert P. Zarky, Sp. Assts. to Atty. Gen., for respondent.

Before CHASE, CLARK, and FRANK, Circuit Judges.


CHASE, Circuit Judge.

The petitioner is a nonresident alien who filed his income tax return for 1940 on the cash basis with the Collector of Internal Revenue for the Southern District of New York. The Commissioner determined a deficiency based in part on the inclusion of $8,673.30 which the taxpayer was paid in that year by Sucro-Blanc, Inc., a New York corporation, under the following circumstances.

Petitioner had invented and patented in this and in some...

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