Abdel-Fattah v. Commissioner
United States Tax Court
In 2005-2007 P, a non-U.S. citizen, was an employee of the Embassy of the United Arab Emirates (UAE) in Washington, D.C., performing for that embassy services of a sort that are performed by employees of the U.S. Embassy in the UAE. The UAE does not impose an income tax, so employees of the U.S. Embassy in the UAE incur no income tax; but the U.S.
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In 2005-2007 P, a non-U.S. citizen, was an employee of the Embassy of the United Arab Emirates (UAE) in Washington, D.C., performing for that embassy services of a sort that are performed by employees of the U.S. Embassy in the UAE. The UAE does not impose an income tax, so employees of the U.S. Embassy in the UAE incur no income tax; but the U.S. Department of State did not certify this fact (pursuant to I.R.C. sec. 893(b)) until 2008. For 2005-2007 P filed tax returns reporting his embassy wages as income. R issued a notice of deficiency for those years based on adjustments unrelated to the…
1Opinion of the Court
OPINION
Gustafson, Judge:
The Internal Revenue Service (irs) issued to petitioner Shoukri Osman Saleh Abdel-Fattah a notice of deficiency pursuant to section 6212, 1 showing the IRS’s determination of the following deficiencies in income tax, additions to tax for failure to file under section 6651(a)(1), and accuracy-related penalties under section 6662 for tax years 2005, 2006, and 2007:
Year Deficiency Addition to tax sec. 6651(a)(1) Accuracy-related penalty sec. 6662
2005 $6,428 $1,285.60
2006 6,465 $343.50 1,293.00
2007 6,858 1,371.60
Mr. Abdel-Fattah brings this case pursuant to section…
2Cases cited15 opinions
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
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