DANT & RUSSELL, INC.
v.
BOARD OF SUPERVISORS OF THE COUNTY OF LOS ANGELES ET AL.

U.S. | 1943-10-11
No. 76
320 U.S. 735 Supreme Court of the United States (1943) Caution
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  • Iglesias v. The United States, 848 F.2d 362 (2d Cir. 1988)
    …ble under § 861, the court is in agreement with apparently the only other circuit court decision concerning the taxability of prejudgment interest received by a nonresident alien. Commissioner v. Raphael, 133 F. 2d 442, 445 (9th Cir.), cert. denied, 320 U.S. 735, 64 S.Ct. 34, 88 L.Ed. 435 (1943) (emphasizing that the term “interest” should be given its common meaning of “compensation for the use or forebearance of money.”) Plaintiff maintains, however, that the prejudgment interest paid by Citibank does no…

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