Frank Murphy

“ Our examination of the record convinces us that the factual inferences and conclusions of the Tax Court are supported by substantial evidence. While decisions as to the purchase and sale of American securities were made in the Edinburgh offices, there was abundant evidence that the American office performed vital functions in the taxpayers' investment trust business. The uncontradicted evidence showed that this office collected dividends from the vast holdings of American securities and did countless other tasks essential to the proper maintenance of a large investment portfolio. ”

“ Commissioner, 45 B.T.A. 243, affirmed in 2 Cir., 128 F.2d 739; B. W. Jones Trust v. Commissioner, 4 Cir., 132 F.2d 914; Fajardo Sugar Co. of Porto Rico v. Commissioner, 20 B.T.A. 980; Recherches Industrielles v. ”