Tweedy v. Commissioner
United States Board of Tax Appeals
1. Petitioner is a United States citizen and was a bona fide nonresident of the United States for more than six months of each of the taxable years. During the taxable years he was a general partner and manager of the London office of a domestic brokerage firm, with respect to which capital was a material income-producing factor. Petitioner at no time contributed capital to the firm, but received a percentage of its profits plus a sum designated "salary."
Read the full summary
1. Petitioner is a United States citizen and was a bona fide nonresident of the United States for more than six months of each of the taxable years. During the taxable years he was a general partner and manager of the London office of a domestic brokerage firm, with respect to which capital was a material income-producing factor. Petitioner at no time contributed capital to the firm, but received a percentage of its profits plus a sum designated "salary." Held, that petitioner's earned income from sources without the United States, excludable from gross income under section 116(a) of the…
1Opinion of the Court
*343OPINION.
Arundell:
The major question presented is whether or not respondent was correct in treating only 20 percent of the amounts received by Tweedy from the partnership as earned income from sources without the United States. Petitioners contend that all the amounts in question constitute compensation for personal services rendered outside this country and as such are excluded from gross income by virtue of the provisions of section 116 (a) of the Revenue Acts of 1936 1 and 1938.2 Respondent argues that the only amounts excluded from gross income under that section are those which constitute…
2Cases cited1 opinion
- Helvering v. Wilshire Oil Co.Supreme Court of the United States · 1939
3Cited by6 opinions
- Foster v. United StatesDistrict Court, S.D. New York · 1963
- Ross v. CommissionerUnited States Tax Court · 1961
- Anderson v. CommissionerUnited States Tax Court · 1981
- Anderson v. CommissionerUnited States Tax Court · 1981
- Ross v. CommissionerUnited States Tax Court · 1961
1 more not listed; retrieve them via the Exa API.