Severino R. Nico, Jr. And Teresita v. Nico v. Commissioner of Internal Revenue

MULLIGAN, Circuit Judge:

Appellants Severino Nico, and his wife, Teresita Nico were Philippine nationals who came to the United States in May, 1971. It is conceded that no income earned by either prior to their residency in the United States is taxable here. The issue is the proper computation of the tax on their income earned in the United States after they assumed residency here. This appeal is from a decision of the United States Tax Court and involves their liability for federal income taxes for the taxable year 1971 which amounts to $150.92 for Severino and $303.81 for Teresita. The facts…