Legal Opinion

Maclean v. Commissioner

United States Tax Court

Decided March 12, 1980No. Docket No. 5178-77Published

P, a citizen of the United Kingdom who first began working in the United States in August 1973, used a fiscal tax year ending Feb. 28, 1974, for his 1973 income tax return. P excluded certain income earned as wages, claiming the amount was exempt under the United States Income Tax Treaty with the United Kingdom.

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P, a citizen of the United Kingdom who first began working in the United States in August 1973, used a fiscal tax year ending Feb. 28, 1974, for his 1973 income tax return. P excluded certain income earned as wages, claiming the amount was exempt under the United States Income Tax Treaty with the United Kingdom. Held: 1. P must follow the calendar tax year in filing, because he did not keep adequate books and records for the fiscal tax year filing requirements under sec. 441(g), I.R.C. 1954; 2. P's income earned while he was working in the United States is not exempt from taxation under terms…

1Opinion of the Court

Ian W. Maclean, Petitioner v. Commissioner of Internal Revenue, Respondent

Maclean v. Commissioner

Docket No. 5178-77

United States Tax Court

73 T.C. 1045; 1980 U.S. Tax Ct. LEXIS 169;

March 12, 1980, Filed

Decision will be entered for the respondent.

P, a citizen of the United Kingdom who first began working in the United States in August 1973, used a fiscal tax year ending Feb. 28, 1974, for his 1973 income tax return. P excluded certain income earned as wages, claiming the amount was exempt under the United States Income Tax Treaty with the United Kingdom. Held:

1. P must follow the calendar tax…

2Cases cited14 opinions

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Burnet v. ClarkSupreme Court of the United States · 1932
  3. Adams v. CommissionerUnited States Tax Court · 1966
  4. Baehre v. CommissionerUnited States Tax Court · 1950
  5. Linen Thread Co. v. CommissionerUnited States Tax Court · 1950

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