Induni v. Commissioner
United States Tax Court
While working for the U.S. Immigration and Naturalization Service in Montreal, Canada, during 1986-88, P received a living quarters allowance (LQA) exempt from Federal income tax under sec. 912(1)(C), I.R.C. R disallowed a portion of Ps' mortgage interest and real estate tax deductions attributable to their residence in Canada during these years.
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While working for the U.S. Immigration and Naturalization Service in Montreal, Canada, during 1986-88, P received a living quarters allowance (LQA) exempt from Federal income tax under sec. 912(1)(C), I.R.C. R disallowed a portion of Ps' mortgage interest and real estate tax deductions attributable to their residence in Canada during these years. R also disallowed some of the moving expenses Ps claimed in 1988, and imposed an addition to tax under sec. 6653(a)(1), I.R.C., for 1988. Held, Ps' mortgage interest and real property tax are indirectly allocable to their tax-exempt LQA, and…
1Opinion of the Court
Noel D. Induni and Janet E. Induni, Petitioners v. Commissioner of Internal Revenue, Respondent
Induni v. Commissioner
Docket No. 8013-90
United States Tax Court
98 T.C. 618; 1992 U.S. Tax Ct. LEXIS 48; 98 T.C. No. 42;
May 20, 1992, Filed
Decision will be entered under Rule 155.
While working for the U.S. Immigration and Naturalization Service in Montreal, Canada, during 1986-88, P received a living quarters allowance (LQA) exempt from Federal income tax under sec. 912(1)(C), I.R.C. R disallowed a portion of Ps' mortgage interest and real estate tax deductions attributable to their residence in…
2Cases cited14 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Neely v. CommissionerUnited States Tax Court · 1985
- Dixon v. United StatesSupreme Court of the United States · 1965
- Luman v. CommissionerUnited States Tax Court · 1982
- United States v. Skelly Oil Co.Supreme Court of the United States · 1969
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