Cook v. Tait

265 U.S. 47 (1924)

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Cook v. Tait

United States Supreme Court
265 U.S. 47 (1924)

Facts

Cook (plaintiff) was a United States citizen and a permanent resident of Mexico domiciled in Mexico. Cook earned income from property in Mexico City. A representative of the United States Internal Revenue Service, Tait (defendant), demanded that Cook pay United States income tax on the Mexico City income. Cook paid under protest and sued to recover the money he had paid, arguing that taxation of income earned outside the borders of the United States by a United States citizen domiciled abroad violated the Due Process Clause of the Fifth Amendment.

Rule of Law

Issue

Holding and Reasoning (McKenna, J.)

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