Estate of Petschek v. Commissioner
United States Tax Court
Throughout 1975, D resided in France. From Jan. 1, 1975, to Nov. 23, 1975, D was an American citizen. On Nov. 24, 1975, D became a citizen of France and remained so through the end of 1975. During 1975, D was the income beneficiary of a simple trust earning all its income from foreign sources.
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Throughout 1975, D resided in France. From Jan. 1, 1975, to Nov. 23, 1975, D was an American citizen. On Nov. 24, 1975, D became a citizen of France and remained so through the end of 1975. During 1975, D was the income beneficiary of a simple trust earning all its income from foreign sources. Held, under sec. 652(a), I.R.C. 1954, in 1975, D is subject to Federal income tax on the net income realized by the trust in that part of the year during which D was an American citizen.
1Opinion of the Court
Estate of Ernst N. Petschek, Deceased, Thomas H. Petschek and Asher Lans, Executors, Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of Petschek v. Commissioner
Docket No. 9428-80
United States Tax Court
81 T.C. 260; 1983 U.S. Tax Ct. LEXIS 44; 81 T.C. No. 20;
September 7, 1983, Filed
Decision will be entered for the respondent.
Throughout 1975, D resided in France. From Jan. 1, 1975, to Nov. 23, 1975, D was an American citizen. On Nov. 24, 1975, D became a citizen of France and remained so through the end of 1975. During 1975, D was the income beneficiary of a simple trust…
2Cases cited37 opinions
- Freuler v. HelveringSupreme Court of the United States · 1934
- Cook v. TaitSupreme Court of the United States · 1924
- Marsman v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
- Marsman v. CommissionerUnited States Tax Court · 1952
- Koufman v. CommissionerUnited States Tax Court · 1977
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