United States Tax Court March 20, 1946, Docket No. 8104 (Kimball v. Commissioner)

lead-opinion

OPINION.

Arundell, Judge:

Article IX of the Convention on Double Taxation Between the United States and The Republic of France,1 executed April 27, 1932, proclaimed April 16, 1935, and effective January 1, 1936, provides:

The following classes of income paid in one of the contracting States * * * to a citizen of the latter State residing there, are exempt from tax in the former