Legal Opinion

Foster v. Commissioner

United States Tax Court

Decided August 27, 1964No. Docket No. 89865Published

Held, petitioner's monthly drawing account, which he received while in Saudi Arabia as a partner of a domestic partnership, represented a distribution of reportable partnership profits and not "guaranteed payments" that would constitute "earned income" from sources without the United States wholly excludable from gross income and exempt from taxation as provided for under section 911(a) of the Internal Revenue Code of 1954.

1Opinion of the Court

Thomas Browne Foster, Petitioner, v. Commissioner of Internal Revenue, Respondent

Foster v. Commissioner

Docket No. 89865

United States Tax Court

42 T.C. 974; 1964 U.S. Tax Ct. LEXIS 51;

August 27, 1964, Filed

Decision will be entered for the respondent.

Held, petitioner's monthly drawing account, which he received while in Saudi Arabia as a partner of a domestic partnership, represented a distribution of reportable partnership profits and not "guaranteed payments" that would constitute "earned income" from sources without the United States wholly excludable from gross income and exempt from…

2Cases cited4 opinions

  1. Falconer v. CommissionerUnited States Tax Court · 1963
  2. Thomas Browne Foster v. United StatesCourt of Appeals for the Second Circuit · 1964
  3. Foster v. United StatesDistrict Court, S.D. New York · 1963
  4. Foster v. CommissionerUnited States Tax Court · 1964

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API