Legal Opinion

Clifford A. Abrahamsen & Sole K. Abrahamsen v. Commissioner

United States Tax Court

Decided June 9, 2014No. Docket 20466-11Unknown

1Opinion of the Court

OPINION

Lauber, Judge:

This case is before the Court on the parties’ cross-motions for summary judgment under Rule 121. The issues for decision are: (1) whether Ms. Abrahamsen’s wages for 2004-09 are exempt from Federal income tax; and (2) whether petitioners are liable for section 6662 accuracy-related penalties. Petitioners resided in New York when they petitioned the Court.

Background

In 1983 Ms. Abrahamsen, a Finnish citizen, came to New York to work for Finland’s Permanent Mission to the United Nations (Mission). The Mission is Finland’s official diplomatic delegation to the United Nations.…

2Cases cited11 opinions

  1. Dahlstrom v. CommissionerUnited States Tax Court · 1985
  2. FPL Group, Inc. v. CommissionerUnited States Tax Court · 2001
  3. Elec. Arts, Inc. v. Comm'rUnited States Tax Court · 2002
  4. City of New York v. Permanent Mission of India to the United NationsCourt of Appeals for the Second Circuit · 2010
  5. United States v. CoplonDistrict Court, S.D. New York · 1949

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