Legal Opinion

Cornman v. Commissioner

United States Tax Court

Decided March 18, 1975No. Docket No. 789-74Published

Petitioner, a United States taxpayer residing in a foreign country, earned no income from biological research activities in 1970. He did, however, deduct expenses related to these activities on his joint Federal income tax return for 1970. Respondent disallowed such expenses on the ground that they were allocable to income which would be exempt from taxation under sec. 911(a), I.R.C. 1954, if earned.

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Petitioner, a United States taxpayer residing in a foreign country, earned no income from biological research activities in 1970. He did, however, deduct expenses related to these activities on his joint Federal income tax return for 1970. Respondent disallowed such expenses on the ground that they were allocable to income which would be exempt from taxation under sec. 911(a), I.R.C. 1954, if earned. Held, petitioner is entitled to deduct the biological research expenses under sec. 162(a), where he received no "earned income" within the intended scope of sec. 911(a) to which his expenses…

1Opinion of the Court

Ivor Cornman, Petitioner v. Commissioner of Internal Revenue, Respondent

Cornman v. Commissioner

Docket No. 789-74

United States Tax Court

63 T.C. 653; 1975 U.S. Tax Ct. LEXIS 180;

March 18, 1975, Filed

Decision will be entered for the petitioner.

Petitioner, a United States taxpayer residing in a foreign country, earned no income from biological research activities in 1970. He did, however, deduct expenses related to these activities on his joint Federal income tax return for 1970. Respondent disallowed such expenses on the ground that they were allocable to income which would be exempt from…

2Cases cited15 opinions

  1. Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
  2. McDonald v. CommissionerSupreme Court of the United States · 1944
  3. Harrow-Taylor Butter Co. v. CrooksCourt of Appeals for the Eighth Circuit · 1930
  4. Hartung v. CommissionerUnited States Tax Court · 1970
  5. Anne Moen Bullitt Brewster v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1973

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