Butka v. Commissioner
United States Tax Court
T, an employee of IBM in Endicott, New York, accepted an assignment from IBM to work abroad for an IBM subsidiary in West Germany. He was thus employed by that subsidiary during the period from May 30, 1981, until Sept. 3, 1983, when he returned to the United States.
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T, an employee of IBM in Endicott, New York, accepted an assignment from IBM to work abroad for an IBM subsidiary in West Germany. He was thus employed by that subsidiary during the period from May 30, 1981, until Sept. 3, 1983, when he returned to the United States. IBM had committed itself at the outset to reimburse T, inter alia, for moving expenses incurred in returning to the United States at the end of the assignment, without any requirement that he continue thereafter to work for IBM. He, in fact, returned to the United States to recommence working for IBM in Endicott, New York. IBM…
1Opinion of the Court
David J. Butka and Sabine I. Butka, Petitioners v. Commissioner of Internal Revenue, Respondent
Butka v. Commissioner
Docket No. 26951-86
United States Tax Court
91 T.C. 110; 1988 U.S. Tax Ct. LEXIS 100; 91 T.C. No. 13;
July 26, 1988July 26, 1988, Filed
Decision will be entered for the respondent.
T, an employee of IBM in Endicott, New York, accepted an assignment from IBM to work abroad for an IBM subsidiary in West Germany. He was thus employed by that subsidiary during the period from May 30, 1981, until Sept. 3, 1983, when he returned to the United States. IBM had committed itself at the outset…
2Cases cited43 opinions
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- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- United States v. CorrellSupreme Court of the United States · 1967
- Bingler v. JohnsonSupreme Court of the United States · 1969
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