Ingram v. Bowers

47 F.2d 925 (1931)

From our private database of 46,300+ case briefs, written and edited by humans—never with AI.

Ingram v. Bowers

United States District Court for the Southern District of New York
47 F.2d 925 (1931)

  • Written by Liz Nakamura, JD

Facts

Enrico Caruso, an Italian citizen and resident, was an internationally famous operatic and concert singer. Caruso entered into an exclusive recording contract with the Victor Talking Machine Company (VTMC), a United States record company. Under the contract, Caruso would be paid a set minimum amount of compensation for each record plus an additional amount based on the total number of sales. VTMC retained all proprietary rights, titles, and copyrights in the records Caruso recorded. All of the records were made and recorded in the United States, but record sales took place both domestically and internationally. All payments were rendered to Caruso in the United States. The Internal Revenue Service (IRS) (defendant) taxed the income Caruso received from all sales of the VTMC records, including foreign sales, and Caruso paid under protest. After Caruso’s death, his widow, Dorothy Caruso Ingram (plaintiff), sued the IRS to recover the taxes Caruso had paid on income derived from foreign record sales. Ingram argued that because Caruso was a nonresident foreign national, the IRS could impose taxes only on income sourced in the United States. The IRS moved for a directed verdict.

Rule of Law

Issue

Holding and Reasoning (Patterson, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 815,000 law students since 2011. Some law schools even subscribe directly to Quimbee for all their law students.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

Here's why 815,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 815,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,300 briefs - keyed to 988 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership