Crerar v. Commissioner
United States Tax Court
Petitioner is a citizen of the United States who was a resident of Canada during 1952. All of her 1952 income was derived from sources within the United States. The question is whether the rate of tax to be imposed upon petitioner's income is a rate set forth in the 1942 Tax Convention between the United States and Canada rather than the rates prescribed in sections 11 and 12, 1939 Code.
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Petitioner is a citizen of the United States who was a resident of Canada during 1952. All of her 1952 income was derived from sources within the United States. The question is whether the rate of tax to be imposed upon petitioner's income is a rate set forth in the 1942 Tax Convention between the United States and Canada rather than the rates prescribed in sections 11 and 12, 1939 Code. Held, under the 1942 Tax Convention with Canada, as amended, the United States reserved the right, in article XVII, to tax the income of its citizens residing in Canada under provisions of the Internal…
1Opinion of the Court
Marie G. Crerar, Petitioner, v. Commissioner of Internal Revenue, Respondent
Crerar v. Commissioner
Docket No. 55532
United States Tax Court
26 T.C. 702; 1956 U.S. Tax Ct. LEXIS 138;
June 27, 1956, Filed
Decision will be entered for the respondent.
Petitioner is a citizen of the United States who was a resident of Canada during 1952. All of her 1952 income was derived from sources within the United States. The question is whether the rate of tax to be imposed upon petitioner's income is a rate set forth in the 1942 Tax Convention between the United States and Canada rather than the rates prescribed…
2Cases cited4 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Brewster v. GageSupreme Court of the United States · 1930
- Lykes v. United StatesSupreme Court of the United States · 1952
- Crerar v. CommissionerUnited States Tax Court · 1956