U.S. Court of Appeals for the District of Columbia Circuit
Grecian Magnesite Mining, Indus. & Shipping Co. v. Comm'r of Internal Revenue Service
This writing
- Type
- Opinion
- Filed
- June 11, 2019
- Case
- Grecian Magnesite Mining, Indus. & Shipping Co. v. Comm'r of Internal Revenue Service
- Case status
- Decided
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Opening text
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Srinivasan, Circuit Judge: Grecian Magnesite Mining, a foreign corporation, realized substantial income when it redeemed its interest in a U.S. partnership. At the time, Grecian operated entirely outside the United States, save for its interest in the partnership. The question we face is whether the geographic origin of the redemption income-its "source"-is within or without the Unit…
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