Adams v. Commissioner
United States Tax Court
Petitioner William, a Canadian citizen, spent about 70 days of each of the years 1957 through 1959 in Florida in a furnished house purchased in 1953 and owned with his wife as a tenant by the entireties. Petitioner Hazel spent 9 to 10 months during each of the 3 years in the house with their children, who attended Florida schools. They spent the remainder of these years in a house in Canada occupied by them for many years, title to which was in Hazel's name.
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Petitioner William, a Canadian citizen, spent about 70 days of each of the years 1957 through 1959 in Florida in a furnished house purchased in 1953 and owned with his wife as a tenant by the entireties. Petitioner Hazel spent 9 to 10 months during each of the 3 years in the house with their children, who attended Florida schools. They spent the remainder of these years in a house in Canada occupied by them for many years, title to which was in Hazel's name. Both made sworn statements to United States and Florida officials that they intended to become United States residents. Held, William…
1Opinion of the Court
Tannenwald, Judge:
Respondent determined deficiencies in petitioners’ Federal income taxes for 1957, 1958, and 1959 in the amounts of $4,431.84, $11,193.23, and $5,127.51, respectively, and asserted an addition to tax of $1,107.96 for 1957 on the ground of failure to file returns. In an amended answer, respondent determined increased deficiencies for these years, 'based on additional interest income from U.S. sources,1 and an increased addition to tax for 1957. The deficiencies were grounded on the subjection of petitioners’ Canadian source income during the 3 years and certain U.S.-source…
2Cases cited20 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Glenn Weible and Patricia Weible v. United StatesCourt of Appeals for the Ninth Circuit · 1957
- Robert A. Henningsen, and Cross and R.A. And Margaret Henningsen v. Commissioner of Internal Revenue, AndCourt of Appeals for the Fourth Circuit · 1957
- Marsman v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
- Marsman v. CommissionerUnited States Tax Court · 1952
15 more not listed; retrieve them via the Exa API.
3Cited by46 opinions
- Dillin v. CommissionerUnited States Tax Court · 1971
- Brittingham v. CommissionerUnited States Tax Court · 1976
- Lemery v. CommissionerUnited States Tax Court · 1970
- Heim v. CommissionerUnited States Tax Court · 1987
- Marsh v. CommissionerUnited States Tax Court · 1977
41 more not listed; retrieve them via the Exa API.