Crow v. Commissioner
United States Tax Court
P's motion for summary judgment that capital gain realized after expatriation is exempt from U.S. tax under the 1942 income tax treaty between United States and Canada. Held, petitioner is not taxable under sec. 877, I.R.C. 1954, notwithstanding the "saving clause" contained in the treaty. Held, further, the treaty does not preclude the United States from taxing imputed interest income under sec. 483, I.R.C. 1954.
1Opinion of the Court
Tedd N. Crow, Petitioner v. Commissioner of Internal Revenue, Respondent
Crow v. Commissioner
Docket No. 32439-83
United States Tax Court
85 T.C. 376; 1985 U.S. Tax Ct. LEXIS 42; 85 T.C. No. 21;
August 26, 1985, Filed
P's motion for summary judgment that capital gain realized after expatriation is exempt from U.S. tax under the 1942 income tax treaty between United States and Canada. Held, petitioner is not taxable under sec. 877, I.R.C. 1954, notwithstanding the "saving clause" contained in the treaty. Held, further, the treaty does not preclude the United States from taxing imputed interest…
2Cases cited35 opinions
- General Electric Co. v. GilbertSupreme Court of the United States · 1976
- Watt v. AlaskaSupreme Court of the United States · 1981
- Reid v. CovertSupreme Court of the United States · 1957
- United States v. CorrellSupreme Court of the United States · 1967
- Zuber v. AllenSupreme Court of the United States · 1970
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