Tweedy v. Commissioner
United States Board of Tax Appeals
1. Petitioner is a United States citizen and was a bona fide nonresident of the United States for more than six months of each of the taxable years. During the taxable years he was a general partner and manager of the London office of a domestic brokerage firm, with respect to which capital was a material income-producing factor. Petitioner at no time contributed capital to the firm, but received a percentage of its profits plus a sum designated "salary."
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1. Petitioner is a United States citizen and was a bona fide nonresident of the United States for more than six months of each of the taxable years. During the taxable years he was a general partner and manager of the London office of a domestic brokerage firm, with respect to which capital was a material income-producing factor. Petitioner at no time contributed capital to the firm, but received a percentage of its profits plus a sum designated "salary." Held, that petitioner's earned income from sources without the United States, excludable from gross income under section 116(a) of the…
1Opinion of the Court
LAWRENCE L. TWEEDY AND GRACE V. TWEEDY, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Tweedy v. Commissioner
Docket Nos. 106646, 107217.
United States Board of Tax Appeals
47 B.T.A. 341; 1942 BTA LEXIS 702;
July 16, 1942, Promulgated
1. Petitioner is a United States citizen and was a bona fide nonresident of the United States for more than six months of each of the taxable years. During the taxable years he was a general partner and manager of the London office of a domestic brokerage firm, with respect to which capital was a material income-producing factor. Petitioner at no time…
2Cases cited2 opinions
- Tweedy v. CommissionerUnited States Board of Tax Appeals · 1942
- Levy v. CommissionerUnited States Board of Tax Appeals · 1942