Seeley v. Commissioner
United States Tax Court
1. Upon the facts, held, petitioner was not a bona fide resident of a foreign country or countries during the taxable years involved within the meaning of section 116 (a) of the Internal Revenue Code. 2. The amount of allowable deduction for medical expense determined.
1Opinion of the Court
OPINION.
Hill, Judge-.
Petitioner contends that he was a bona fide resident of a foreign country or countries for the years involved within the meaning of section 116 (a) of the Internal Bevenue Code,1 because:
His status as a resident of Sweden was unimpaired by Ms absence therefrom during the taxable years, since such absence was an enforced one beyond his control and he at all times intended to, and he did, in fact, return to that country .as soon as possible.
He also argues:
In the alternative, .petitioner became a resident of England when he went there on June 20,1942, since his assignment…
2Cases cited2 opinions
- Johnson v. CommissionerUnited States Tax Court · 1946
- Baer v. CommissionerUnited States Tax Court · 1946
3Cited by28 opinions
- Commissioner of Internal Revenue v. NubarCourt of Appeals for the Fourth Circuit · 1950
- Nelson v. CommissionerUnited States Tax Court · 1958
- Meade A. Carpenter, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1974
- Jellinek v. CommissionerUnited States Tax Court · 1961
- Weeks v. CommissionerUnited States Tax Court · 1951
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