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DE VEGVAR v. COMMISSIONER

Docket No. 58742.

28 T.C. 1055 (1957)

EDWARD A. NEUMAN DE VEGVAR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 27, 1957.

Attorney(s) appearing for the Case

Milton Ross, Esq., for the petitioner.

Rutheled B. Wolter, Esq., for the respondent.

OPINION.

RAUM, Judge:

Respondent determined a deficiency in petitioner's income tax for the year 1948 in the amount of $8,744.84. At issue in this proceeding is whether respondent was correct in concluding that petitioner's capital gains were taxable because he was a nonresident alien "engaged in trade or business in the United States" within the meaning of section 211 (b) of the Internal Revenue Code of 19391 during the...

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