Legal Opinion

Dillin v. Commissioner

United States Tax Court

Decided May 6, 1971No. Docket Nos. 5050-67, 5051-67Published

Prior to September 1963, petitioners, husband and wife, were both U.S. citizens and resident-domiciliaries of Texas. During 1958 H performed certain services. By agreement entered into with S corporation in July 1958, he was compensated for these services and received payments in 1963, 1964, and 1965. In September 1963, shortly before he received the first payment, H renounced his U.S. citizenship and became a resident of the Bahamas.

Read the full summary

Prior to September 1963, petitioners, husband and wife, were both U.S. citizens and resident-domiciliaries of Texas. During 1958 H performed certain services. By agreement entered into with S corporation in July 1958, he was compensated for these services and received payments in 1963, 1964, and 1965. In September 1963, shortly before he received the first payment, H renounced his U.S. citizenship and became a resident of the Bahamas. W accompanied him to the Bahamas but retained her U.S. citizenship. Held, despite the fact that H was a U.S. citizen when he earned the amounts in question he…

1Opinion of the Court

William N. Dillin, Petitioner v. Commissioner of Internal Revenue, Respondent; Patrea L. Dillin, Petitioner v. Commissioner of Internal Revenue, Respondent 1

Dillin v. Commissioner

Docket Nos. 5050-67, 5051-67

United States Tax Court

56 T.C. 228; 1971 U.S. Tax Ct. LEXIS 137;

May 6, 1971, Filed

Decisions will be entered under Rule 50.

Prior to September 1963, petitioners, husband and wife, were both U.S. citizens and resident-domiciliaries of Texas. During 1958 H performed certain services. By agreement entered into with S corporation in July 1958, he was compensated for these services and received…

2Cases cited25 opinions

  1. Poe v. SeabornSupreme Court of the United States · 1930
  2. Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
  3. Marcello v. CommissionerUnited States Tax Court · 1964
  4. Hopkins v. BaconSupreme Court of the United States · 1930
  5. Cook v. TaitSupreme Court of the United States · 1924

20 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API