Unpublished Opinions United States Court of Appeals for the Ca4 Uscourts Form

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oh o OA all persons having business before The Honorable the United States court of appeals for the District of Colombia circuit or manage to draw near and give their attention the court is now sitting God save the United States and this honorable Court be seated please case number 23- 11142 andu Rob appellant versus Commissioner of internal revenue Mr reac for the appellant Mr reny for the AAL good morning Council Mr reac please proceed ready you're ready morning your honor uh my name is Chris rizik I am Council for theant um indu rawat at the council table is my co-council Lea Carney this is a federal tax case involving the source of income when a foreign person sells a US partnership interest in that respect it's very similar to the involves the same general rule as this Court's opinion in Grecian magnesite in 2019 that general rule being that income from the sale of personal property ass sourc to the residents of the seller and at this time in 20 2008 Mrs rawat was a resident of uh