* As to the status of foreign administrative determinations under the full faith and credit clause of the Federal Constitution, see City of Philadelphia v. Cohen, 11 N.Y. 2d 401, and the citations in Judge Fuld’s dissenting opinion. While that case dealt primarily with the effect of the full faith and credit clause, it also held that comity does not require enforcement of a tax liability imposed by a foreign administrative agency, although the liability had become final by reason of the taxpayer’s failure to seek a review. The emphasis of the decision was on the nature of the liability, and we perceive no intimation that, where the liability is one which our courts would recognize under comity if determined by a foreign court, recognition is to be withheld merely because the determination, though it has achieved finality, is the product of a foreign administrative agency (cf. Restatement of Law, Conflict of Laws, sees. 71, 429). [Footnote in the Court’s opinion]

* [Banco Nacional de Cuba v. Sabbatino, 307 F. 2d 845 (2d Cir. 1962), 1 International Legal Materials 1 (1962), 56 A.J.I.L. 1085 (1962).]

* [163 F. 2d 246 (2d. Cir. 1947), cert. den. 332 U.S. 772 (1947). See Bernstein v. N.V. Nederlandsche-Amerikaansche Stoomvaart-Maatschappij. 210 F. 2d 375 (2d. Cir. 1954) (per curiam).

Ed. note]

* [Filed December 28, 1962. The opinion of the Court of Appeals is reported at 307 F. 2d 845 (2d Cir. 1962), 1 International Legal Materials 1 (1962), 56 A.J.I.L. 1085 (1962). The District Court opinion is reported at 193 F. Supp. 375 (S.D. N.Y. 1961), digested, 55 A.J.I.L. 741 (1961).]

* [Not reprinted.]

** [Noted, 2 International Legal Materials 209 (1963).]

* [Not reprinted.]

** [The proceedings in the Supreme Court before Chief Justice Warren in these cases in September 1961, including memoranda for the United States, are reported at 1 International Legal Materials 276 (1962).]

1 The Solicitor General’s merely acknowledged receipt of the letter.