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KARRER v. UNITED STATES

No. 485-52.

152 F.Supp. 66 (1957)

Paul KARRER v. The UNITED STATES.

United States Court of Claims.

May 8, 1957.

Attorney(s) appearing for the Case

Roswell Magill, New York City, for the plaintiff. Albert Rosenblum, New York City, was on the briefs.

Gerard J. O'Brien, Washington, D. C., with whom was Charles K. Rice, Asst. Atty. Gen., for the defendant. Andrew D. Sharpe and Jerome S. Hertz, Washington, D. C., were on the brief.

Before JONES, Chief Judge, and LITTLETON, WHITAKER, MADDEN and LARAMORE, Judges.

LITTLETON, Judge.

This is an action to recover $201,504.88 in Federal income taxes which plaintiff alleges were erroneously and illegally assessed and collected from him for the years 1941 to 1946, inclusive. The question presented is whether payments made by a domestic corporation to a nonresident alien under a contract between the nonresident alien and a nonresident foreign corporation constitute income to the individual from sources within the United States for...

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