Dillin v. Commissioner
United States Tax Court
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.
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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
- Poe v. SeabornSupreme Court of the United States · 1930
- 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
- Marcello v. CommissionerUnited States Tax Court · 1964
- Hopkins v. BaconSupreme Court of the United States · 1930
- Cook v. TaitSupreme Court of the United States · 1924
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