Matthews v. Commissioner
United States Tax Court
Ps were employed by nonappropriated fund instrumentalities of the United States while living in Germany. Held, Ps were employees of an agency of the United States for purposes of sec. 911(b)(1)(B), I.R.C. 1954, and accordingly are not entitled to elect to exclude foreign earned income under sec. 911.
1Opinion of the Court
Colvin, Judge:
The issues for decision are:(1) May petitioners1 exclude from gross income as foreign earned income under section 9112 certain wages paid by a nonappropriated fund instrumentality of the United States while located in the Federal Republic of Germany during the taxable years at issue.(2) If petitioners are not eligible to make the election under section 911, were the underpayments of tax due to negligence or intentional disregard of rules or regulations under section 6653(a).
Section 911 allows a qualified individual to elect to exclude limited amounts of foreign earned income…
2Cases cited25 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Neely v. CommissionerUnited States Tax Court · 1985
- Bixby v. CommissionerUnited States Tax Court · 1972
- Commissioner v. JacobsonSupreme Court of the United States · 1949
- Standard Oil Co. of Cal. v. JohnsonSupreme Court of the United States · 1942
20 more not listed; retrieve them via the Exa API.
3Cited by56 opinions
- Bokum v. CommissionerUnited States Tax Court · 1990
- Michael D. Weber Barbara L. Weber v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Fourth Circuit · 1995
- Weber v. CommissionerUnited States Tax Court · 1994
- David W. Matthews and Christa Matthews, Ronald Davis and Marie Davis v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1990
- BUNNEY v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2000
51 more not listed; retrieve them via the Exa API.