Teskey v. Commissioner
United States Tax Court
A citizen of the United States, employed as a radio operator on a vessel owned by an agency of the United States and operated by the United States under a contract with a private shipping firm as agent, in shuttle service between Korea and Japan during the Korean War emergency, was paid by a private shipping line as agent of the United States from funds provided specifically for that purpose by the United States.
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A citizen of the United States, employed as a radio operator on a vessel owned by an agency of the United States and operated by the United States under a contract with a private shipping firm as agent, in shuttle service between Korea and Japan during the Korean War emergency, was paid by a private shipping line as agent of the United States from funds provided specifically for that purpose by the United States. Held, such compensation constitutes an amount paid by the United States or any agency thereof within the meaning of section 116 (a) I. R. C. 1939, and section 911 (a) I. R. C. 1954,…
1Opinion of the Court
The Commissioner has determined deficiencies in petitioner’s income tax for the years 1953 and 1954 in the respective amounts of $2,366.91 and $1,278.04. The explanation in the deficiency notice of the deficiency for 1953 is as follows:
You have failed to show that for the year 1953 you qualified as a bona fide resident of a foreign country, within the meaning of Section 116 (a) of the Internal Revenue Code, for an uninterrupted period which includes an entire taxable year. You have also failed to show that your foreign employment was part of a period of 18 consecutive months during which you…
2Cases cited1 opinion
- Sverdrup v. CommissionerUnited States Tax Court · 1950
3Cited by31 opinions
- John D. McComish and Genevieve A. McComish v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1978
- Commissioner of Internal Revenue v. Eldon E. Wolfe and Sara A. WolfeCourt of Appeals for the D.C. Circuit · 1966
- George Y. Erlandson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
- Donaldson v. CommissionerUnited States Tax Court · 1969
- Wolfe v. CommissionerUnited States Tax Court · 1965
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