Christensen v. Commissioner
United States Tax Court
Petitioners resided in Puerto Rico from 1966 through 1969. After returning to the United States, petitioners were notified that their Puerto Rican tax returns were to be the subject of an audit by the Puerto Rican Bureau of Income Tax. In connection with this audit, petitioners incurred certain legal and accounting expenses which they deducted on their 1972 and 1973 Federal income tax returns.
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Petitioners resided in Puerto Rico from 1966 through 1969. After returning to the United States, petitioners were notified that their Puerto Rican tax returns were to be the subject of an audit by the Puerto Rican Bureau of Income Tax. In connection with this audit, petitioners incurred certain legal and accounting expenses which they deducted on their 1972 and 1973 Federal income tax returns. Held, petitioners' expenses are "properly allocable to or chargeable against" income exempted by sec. 933(1), I.R.C. 1954, and, therefore, are not deductible.
1Opinion of the Court
OPINION
Fay, Judge:
Respondent determined deficiencies in petitioners’ Federal income taxes as follows:
Year Deficiency
1972 $2,738
1973 3,739
The sole issue for decision is whether section 933(1)1 precludes petitioners from deducting under section 212(3) certain legal and accounting expenses incurred by them in connection with an audit of their 1966 through 1969 Puerto Rican income tax returns conducted by the Puerto Rican Bureau of Income Tax.
All of the facts have been stipulated and are so found.
At the time of filing their petition herein, petitioners Lauge H. Christensen and his wife, Helen S.…
2Cases cited6 opinions
- Anne Moen Bullitt Brewster v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1973
- Brewster v. CommissionerUnited States Tax Court · 1970
- Hughes v. CommissionerUnited States Tax Court · 1975
- Roque v. CommissionerUnited States Tax Court · 1976
- Cornman v. CommissionerUnited States Tax Court · 1975
1 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Butka v. CommissionerUnited States Tax Court · 1988
- Maestre v. CommissionerUnited States Tax Court · 1979
- Butka v. CommissionerUnited States Tax Court · 1988
- Christensen v. CommissionerUnited States Tax Court · 1978
- Maestre v. CommissionerUnited States Tax Court · 1979