Thorsell v. Commissioner
United States Tax Court
Petitioner was assigned by his employer, the Travelers Insurance Co., to act as resident claims representative in Nassau, Bahama Islands, British West Indies. His work was in connection with workmen's compensation claims arising out of the work of a United States contractor who was building two airfields for the British Royal Air Force.
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Petitioner was assigned by his employer, the Travelers Insurance Co., to act as resident claims representative in Nassau, Bahama Islands, British West Indies. His work was in connection with workmen's compensation claims arising out of the work of a United States contractor who was building two airfields for the British Royal Air Force. He and his employer expected that the project would be completed in 3 to 6 months, but petitioner was expected to stay until the project was completed. In fact, he remained 19 months, from June 1942 to January 1944. He lived in hotels and this expense plus…
1Opinion of the Court
OPINION.
Arundell, Judge:
The question which is presented in this case is whether the petitioner was throughout the year 1943 a bona fide resident of Nassau within the meaning of section 116 (a) (1) of the Internal Revenue Code,1 as amended by section 148 (a) of the Revenue Act of 1942, so as to be entitled to the exemption for taxes on his earnings in Nassau.
Prior to the amendment of the statute in 1942, physical absence from the United States for a period of six months in the year was sufficient to constitute one a bona fide nonresident in the United States and thus relieve from taxation…
2Cases cited3 opinions
- Johnson v. CommissionerUnited States Tax Court · 1946
- Downs v. CommissionerUnited States Tax Court · 1946
- Warren v. CommissionerUnited States Tax Court · 1949
3Cited by24 opinions
- Owens v. CommissionerUnited States Tax Court · 1968
- Nelson v. CommissionerUnited States Tax Court · 1958
- Milleg v. CommissionerUnited States Tax Court · 1952
- Meals v. United StatesDistrict Court, N.D. California · 1953
- Weeks v. CommissionerUnited States Tax Court · 1951
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