BRUSWITZ ET AL.

v.

UNITED STATES

Citator

Cited By

• United States v. Moran, 236 F.2d 361 (2d Cir. 1956)
  …t, we cannot say that the discretion was improperly exercised. 2. The extortion receipts were clearly taxable. Rutkin v. United States, 343 U.S. 130, 72 S.Ct. 571, 96 L.Ed. 833. See United States v. Bruswitz, 2 Cir., 218 F. 2d 59, certiorari denied 349 U.S. 913, 75 S.Ct. 600, 99 L.Ed. 1247. 3. There was sufficient evidence of willfulness in “a consistent pattern of underreporting large amounts of income.” See Holland v. United States, 349 U.S. 121, 75 S.Ct. 127, 99 L.Ed. 150. It is asserted in defendant’s…
• Wacker v. Bisson, 348 F.2d 602 (5th Cir. 1965)
  …n or sovereign such as the Dominion of Canada or against its New Orleans Consul General as the representative of the sovereign, the Dominion of Canada. National City Bank of New York v. Republic of China, 348 U.S. 356, 75 S.Ct. 423 (1955), reh. den. 349 U.S. 913, 75 S.Ct. 598, 99 L.Ed. 389; Matthews v. Walton Rice Mill, 1949, 85 U.S.App.D.C. 197, 176 F. 2d 69; United States ex rel. Cardashian v. Snyder, D.C., 1930, 44 F. 2d 895, cert. den. 283 U.S. 827, 51 S.Ct. 351, 75 L.Ed. 1440. Since the Consul is bein…
• Commissioner OF Internal Revenue v. Gross, 236 F.2d 612 (2d Cir. 1956)
  …Act of 1934, 15 U.S.C. § 78p(b), likewise includable in gross receipts. Compare also Rutkin v. United States, 343 U.S. 130, 72 S.Ct. 571, 96 L.Ed. 833, and United States v. Bruswitz, 2 Cir., 219 F. 2d 59, certiorari denied Bruswitz v. United States, 349 U.S. 913, 75 S.Ct. 600, 99 L.Ed. 1247, as to the proceeds of extortion; and see discussion in Rapp, Some Recent Developments in the Concept of Taxable Income, 11 Tax L.Rev. 329, 331, 358-371 (1956). On the other hand, the preferential capital gains provisio…