Legal Opinion

Ossorio v. Commissioner

United States Tax Court

Decided January 5, 1943No. Docket No. 108499Published

The petitioner is a citizen and a resident of the United States and his wife is a citizen and resident of the Philippine Islands.

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The petitioner is a citizen and a resident of the United States and his wife is a citizen and resident of the Philippine Islands. They filed separate income tax returns for 1937 with the Philippine taxing authorities, that of the petitioner showing a net income of 1,399,687.61 pesos ($ 699,848.81) and that of the wife a net income of 235,234.10 pesos ($ 117,617.05). Pursuant to the provisions of the Philippine income tax law, the returns were consolidated for the purpose of computing the tax due from the marital community and a tax of $ 165,763.65 was determined, of which the petitioner paid…

1Opinion of the Court

Miguel Jose Ossorio, Petitioner, v. Commissioner of Internal Revenue, Respondent

Ossorio v. Commissioner

Docket No. 108499

United States Tax Court

1 T.C. 410; 1943 U.S. Tax Ct. LEXIS 262;

January 5, 1943, Promulgated

Decision will be entered under Rule 50.

The petitioner is a citizen and a resident of the United States and his wife is a citizen and resident of the Philippine Islands. They filed separate income tax returns for 1937 with the Philippine taxing authorities, that of the petitioner showing a net income of 1,399,687.61 pesos ($ 699,848.81) and that of the wife a net income of 235,234.10…

2Cases cited1 opinion

  1. Ossorio v. CommissionerUnited States Tax Court · 1943

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