Roque v. Commissioner
United States Tax Court
Petitioners incurred $ 2,484.30 of moving expenses qualifying for deduction under sec. 217, I.R.C. 1954, when they moved from New York to Puerto Rico during November 1971. All Puerto Rican source income earned by petitioners subsequent to this move would be exempt from Federal income taxation through the operation of sec. 933(1), I.R.C. 1954. Held: In the absence of any evidence that petitioners earned income subject to Federal income tax after moving to Puerto Rico,…
Read the full summary
Petitioners incurred $ 2,484.30 of moving expenses qualifying for deduction under sec. 217, I.R.C. 1954, when they moved from New York to Puerto Rico during November 1971. All Puerto Rican source income earned by petitioners subsequent to this move would be exempt from Federal income taxation through the operation of sec. 933(1), I.R.C. 1954. Held: In the absence of any evidence that petitioners earned income subject to Federal income tax after moving to Puerto Rico, petitioners' moving expense deduction must be disallowed because those expenses were properly allocable to or chargeable…
1Opinion of the Court
OPINION
Dawson, Chief Judge:
Respondent determined a deficiency of $411.35 in petitioners’ Federal income tax for the calendar year 1971. The only issue presented for our decision is whether petitioners are prohibited by section 933(1), I.R.C. 1954,1 from deducting $2,484.30 of moving expenses, which otherwise qualify for deduction under section 217, because they are properly allocable to or chargeable against tax-exempt income derived from sources within Puerto Rico.
All of the facts have been stipulated by the parties in accordance with Rule 122, Tax Court Rules of Practice and Procedure. We…
2Cases cited5 opinions
- Hartung v. CommissionerUnited States Tax Court · 1970
- Donaldson v. CommissionerUnited States Tax Court · 1969
- Hughes v. CommissionerUnited States Tax Court · 1975
- Hartung v. CommissionerCourt of Appeals for the Ninth Circuit · 1973
- Markus v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1973
3Cited by10 opinions
- Butka v. CommissionerUnited States Tax Court · 1988
- Christensen v. CommissionerUnited States Tax Court · 1978
- Maestre v. CommissionerUnited States Tax Court · 1979
- Narain v. CommissionerUnited States Tax Court · 1983
- Painter v. CommissionerUnited States Tax Court · 1976
5 more not listed; retrieve them via the Exa API.