Legal Opinion

Brewster v. Commissioner

United States Tax Court

Decided October 29, 1970No. Docket No. 3672-67PublishedCited by 19 opinions

Held, the Commissioner properly determined that petitioner, who had earned income from sources without the United States, could not claim a deduction from gross income, of a portion of her expenses, since a portion of such expenses was properly allocable to or chargeable against amounts excluded from gross income. Sec. 911(a) and (b), I.R.C. 1954.

1Opinion of the Court

Tiet.teNS, Judge:

The Commissioner determined deficiencies in petitioner’s Federal income tax for the years 1957 through 1960 as follows:

Year Deficiency

1957 _$14,296. 77

1958 _ 12,439.58

1959 _ 29, Oil. 45

1960 - 17,900.73

Taxable year 1956 is also involved herein but only so far as it relates to a net operating loss in that year which was carried forward to 1957 and deducted therein.

The primary issue for our determination is whether during the years in question certain expenses claimed as deductions by petitioner are allowable or are disallowed by section 911(a), I.R.C. 1954,1 as being “properly…

2Cases cited2 opinions

  1. KIRO, Inc. v. CommissionerUnited States Tax Court · 1968
  2. Hempel v. CommissionerUnited States Tax Court · 1947

3Cited by19 opinions

  1. Anne Moen Bullitt Biddle Brewster v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1979
  2. Bruno v. CommissionerUnited States Tax Court · 1978
  3. Cook v. United StatesUnited States Court of Claims · 1979
  4. Anne Moen Bullitt Brewster v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1973
  5. Brewster v. CommissionerUnited States Tax Court · 1976

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