Chapman v. Commissioner
United States Tax Court
1. Income -- Exclusions or Exemptions -- Sections 22 (a), 22 (b) (8), 116 (h). -- The compensation of an official of the League of Nations temporarily residing in this country for several war years and conducting his official duties here is subject to income tax under section 22 (a) and is not relieved therefrom by 22 (b) (8) and 116 (h), I. R. C. 2. Income -- Deductions -- Traveling Expenses -- Section 23 (a). -- His living expenses at his residence and place of business in…
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1. Income -- Exclusions or Exemptions -- Sections 22 (a), 22 (b) (8), 116 (h). -- The compensation of an official of the League of Nations temporarily residing in this country for several war years and conducting his official duties here is subject to income tax under section 22 (a) and is not relieved therefrom by 22 (b) (8) and 116 (h), I. R. C. 2. Income -- Deductions -- Traveling Expenses -- Section 23 (a). -- His living expenses at his residence and place of business in this country are not deductible as traveling expenses.
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner determined deficiencies in income tax as follows:
1942_ $163.17
1943_ 300. 02
1944_ 1,822.37
The petitioner contends that his income is not included in gross income under section 22 (a) of the Internal Revenue Code and, in the alternative, that it is expressly excluded under sections 22 (b) (8) and 116 (h). He also claims a deduction for traveling expenses. The facts have been stipulated.
The petitioner was a citizen of New Zealand at all times material hereto. He filed nonresident alien returns for 1942 and 1943 with the collector of internal revenue for…
2Cases cited4 opinions
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Irwin v. GavitSupreme Court of the United States · 1925
- Johnson v. CommissionerUnited States Tax Court · 1946
- Downs v. CommissionerUnited States Tax Court · 1946
3Cited by27 opinions
- Brittingham v. CommissionerUnited States Tax Court · 1976
- Schoneberger v. CommissionerUnited States Tax Court · 1980
- De La Begassiere v. CommissionerUnited States Tax Court · 1959
- Ying v. CommissionerUnited States Tax Court · 1992
- Harris v. CommissionerUnited States Tax Court · 1948
22 more not listed; retrieve them via the Exa API.