Renoir v. Commissioner
United States Tax Court
Petitioners received in 1956 and 1957 earned income from sources outside the United States attributable to an 18-month period ending in 1956. Held, the amount of such income excludible from gross income in 1956 is a fraction of $ 20,000 based upon the number of days of the 18-month period contained in the taxable year, and no amount is excludible in 1957. Sec. 911(a)(2), I.R.C. 1954.
1Opinion of the Court
OPINION.
Bruce, Judge:
The respondent determined deficiencies for the calendar years 1956 and 1957 in the respective amounts of $9,318.37 and $2,441.19. The sole issue for decision is the extent to which amounts received hi the taxable years for personal services performed in France are excludible from taxable income. All the facts are stipulated and are found accordingly.
The petitioners, husband and wife, were residents and domiciled in California during the years at issue. They filed joint Federal income tax returns for the calendar years 1956 and 1957 with the director of internal revenue at…
2Cases cited1 opinion
- Ross v. CommissionerUnited States Tax Court · 1961
3Cited by14 opinions
- Zaffaroni v. CommissionerUnited States Tax Court · 1976
- Jean Renoir and Dido Freire Renoir v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- Ebberts v. CommissionerUnited States Tax Court · 1968
- Alan W. Ladd and Sue Carol Ladd v. Robert A. Riddell, District Director of Internal Revenue, Los Angeles, California, Etc.Court of Appeals for the Ninth Circuit · 1962
- Cornman v. CommissionerUnited States Tax Court · 1975
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