Legal Opinion

Hudson v. Commissioner

United States Tax Court

Decided August 25, 1953No. Docket No. 38356Published

The United States Educational Foundation in China was an instrumentality of the United States and was under the general control of the Secretary of State. The salary and allowances of petitioner as an officer of the Foundation were fixed with the approval of the State Department in accordance with its regulations governing the pay and allowances of Foreign Service officers and employees.

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The United States Educational Foundation in China was an instrumentality of the United States and was under the general control of the Secretary of State. The salary and allowances of petitioner as an officer of the Foundation were fixed with the approval of the State Department in accordance with its regulations governing the pay and allowances of Foreign Service officers and employees. Cost-of-living allowances so paid petitioner are excludible from her gross income under section 116 (j) of the Internal Revenue Code.

1Opinion of the Court

Shirley Duncan Hudson, Petitioner, v. Commissioner of Internal Revenue, Respondent

Hudson v. Commissioner

Docket No. 38356

United States Tax Court

20 T.C. 926; 1953 U.S. Tax Ct. LEXIS 77;

August 25, 1953, Promulgated

Decision will be entered under Rule 50.

The United States Educational Foundation in China was an instrumentality of the United States and was under the general control of the Secretary of State. The salary and allowances of petitioner as an officer of the Foundation were fixed with the approval of the State Department in accordance with its regulations governing the pay and allowances…

2Cases cited2 opinions

  1. Brunelle v. CommissionerUnited States Tax Court · 1950
  2. Hudson v. CommissionerUnited States Tax Court · 1953

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