1.Carlson, a citizen and resident of Denmark, is a commoditiesdealer operating in Copenhagen. During the tax year, Carlson, bye-mail from her home office, purchased several carloads of wheat.She took title to the wheat in Minneapolis. The wheat was sold tothe government of India, FOB New York City, where the wheat wasplaced aboard a Liberian flag vessel. Carlson has never been to theUnited States. While she has occasionally purchased U.S.commodities in the past, this is her sole transaction in the UnitedStates during the current year. Does she have any potential U.S.income tax liability? 5. Rosario, a corporation organized inArgentina, sells consumer products to retailers in the main citiesof that country. Rosario has no office in the United States.

2.Rosario sales representatives in Argentina send orders to apurchasing agent in New York. The purchasing agent purchases theproducts from U.S. manufacturers in Rosario’s name. The productsare shipped to Miami and delivered to vessels bound for Argentina.Orders are accepted in Argentina. Title to the goods is transferredto customers at the port of destination. However, the customershave agreed contractually to insure against all losses attributableto shipwreck, fire and accident while the goods are in transit. TheArgentine customers make payment to an account maintained byRosario in Switzerland. Does Rosario have any liability for U.S.taxes? Would your answer differ if the purchasing agent is properlycharacterized as an “independent agent”?