Jan Casimir Lewenhaupt v. Commissioner of Internal Revenue

Ninth Circuit

Jan Casimir Lewenhaupt v. Commissioner of Internal Revenue

221 F.2d 227

CourtCourt of Appeals for the Ninth Circuit

DecidedMay 16, 1955

Docket14069_1

StatusPublished

Cited by24 cases

This text of 221 F.2d 227 (Jan Casimir Lewenhaupt v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Jan Casimir Lewenhaupt v. Commissioner of Internal Revenue, 221 F.2d 227 (9th Cir. 1955).

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Opinion

PER CURIAM.

This case, here on petition for review of a decision of the Tax Court, involves the interpretation of Articles V and IX of the tax convention between the United States and Sweden, and the validity of section 25.6 of the Commissioner’s regulations.

The petitioner, a citizen and resident of Sweden, in 1946 sold real property situated in the United States, realizing gain from the sale thereof. The Tax Court sustained a ruling of the Commissioner holding the gain to be subject to tax under §§ 211(b) and 117 of the Internal Revenue Code, 26 U.S.C.A.

The Court’s findings of fact and opinion are reported in 20 T.C. 151. The findings appear amply supported, and we are in agreement with the conclusions reached. The decision is accordingly affirmed for the reasons given by the Tax Court.

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PER CURIAM.

This case, here on petition for review of a decision of the Tax Court, involves the interpretation of Articles V and IX of the tax convention between the United States and Sweden, and the validity of section 25.6 of the Commissioner’s regulations.

The petitioner, a citizen and resident of Sweden, in 1946 sold real property situated in the United States, realizing gain from the sale thereof. The Tax Court sustained a ruling of the Commissioner holding the gain to be subject to tax under §§ 211(b) and 117 of the Internal Revenue Code, 26 U.S.C.A.

The Court’s findings of fact and opinion are reported in 20 T.C. 151. The findings appear amply supported, and we are in agreement with the conclusions reached. The decision is accordingly affirmed for the reasons given by the Tax Court.

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221 F.2d 227, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jan-casimir-lewenhaupt-v-commissioner-of-internal-revenue-ca9-1955.

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