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.)
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