Legal Opinion

Induni v. Commissioner

United States Tax Court

Decided May 20, 1992No. Docket No. 8013-90PublishedCited by 3 opinions

While working for the U.S. Immigration and Naturalization Service in Montreal, Canada, during 1986-88, P received a living quarters allowance (LQA) exempt from Federal income tax under sec. 912(1)(C), I.R.C. R disallowed a portion of Ps' mortgage interest and real estate tax deductions attributable to their residence in Canada during these years.

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While working for the U.S. Immigration and Naturalization Service in Montreal, Canada, during 1986-88, P received a living quarters allowance (LQA) exempt from Federal income tax under sec. 912(1)(C), I.R.C. R disallowed a portion of Ps' mortgage interest and real estate tax deductions attributable to their residence in Canada during these years. R also disallowed some of the moving expenses Ps claimed in 1988, and imposed an addition to tax under sec. 6653(a)(1), I.R.C., for 1988. Held, Ps' mortgage interest and real property tax are indirectly allocable to their tax-exempt LQA, and…

1Opinion of the Court

OPINION

DAWSON, Judge:

This case was assigned to Special Trial Judge Francis J. Cantrel pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

CANTREL, Special Trial Judge:

By statutory notice of deficiency dated February 5, 1990, respondent determined the following deficiencies and an addition to tax in petitioners' Federal income taxes:

Year Deficiency Addition to tax sec. 6653(a)(1)

1986 $3,458

1987 2,399

1988 2,842 $142.10

The deficiencies result from…

2Cases cited13 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Neely v. CommissionerUnited States Tax Court · 1985
  3. Dixon v. United StatesSupreme Court of the United States · 1965
  4. Luman v. CommissionerUnited States Tax Court · 1982
  5. United States v. Skelly Oil Co.Supreme Court of the United States · 1969

8 more not listed; retrieve them via the Exa API.

3Cited by3 opinions

  1. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  2. Stroud v. United StatesDistrict Court, D. South Carolina · 1995
  3. Induni v. CommissionerUnited States Tax Court · 1992

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