Kronenberg v. Commissioner
United States Tax Court
The petitioner renounced his U.S. citizenship 1 day before liquidating distributions were transferred to him. Held, one of the principal purposes for such loss of citizenship was to avoid Federal income taxes on the distributions, and the gains on such distributions are taxable under sec. 877, I.R.C. 1954; held, further, the fair market value of a note received in the distributions determined; held, further, expenses incurred in moving to Switzerland are not deductible under…
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The petitioner renounced his U.S. citizenship 1 day before liquidating distributions were transferred to him. Held, one of the principal purposes for such loss of citizenship was to avoid Federal income taxes on the distributions, and the gains on such distributions are taxable under sec. 877, I.R.C. 1954; held, further, the fair market value of a note received in the distributions determined; held, further, expenses incurred in moving to Switzerland are not deductible under sec. 877(b)(2), I.R.C. 1954.
1Opinion of the Court
Simpson, Judge:
The Commissioner determined a deficiency of $98,344.76 in the petitioner’s Federal income tax for the year 1967. Some concessions have been made; the issues remaining for decision are: (1) Whether liquidating distributions received by the petitioner after he became a nonresident alien are taxable under section 877 of the Internal Revenue Code of 1954,1 relating to expatriation to avoid tax; (2) the fair market value of a note distributed in the liquidation; and (3) whether expenses incurred in moving to Switzerland are deductible under section 877(b)(2).
FINDINGS OF FACT
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2Cases cited14 opinions
- 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
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Marcello v. CommissionerUnited States Tax Court · 1964
- Marco v. CommissionerUnited States Tax Court · 1955
- Williams v. CommissionerUnited States Tax Court · 1957
9 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Crow v. CommissionerUnited States Tax Court · 1985
- Estate of Petschek v. CommissionerUnited States Tax Court · 1983
- Di Portanova v. United StatesUnited States Court of Claims · 1982
- Furstenberg v. CommissionerUnited States Tax Court · 1984
- Estate of Friedberg v. CommissionerUnited States Tax Court · 1992
5 more not listed; retrieve them via the Exa API.