Fink v. Commissioner
United States Tax Court
Petitioners, residents of Washington, were present in a foreign country for more than the requisite 18 months (sec. 911(a)(2), I.R.C. 1954) while husband served in the U.S. Navy. They excluded half of his Navy salary in 1965 and 1966 and such exclusions were disallowed by the Commissioner. Court of Claims has held that the determination for 1965 was not unconstitutional, Fink v. United States, 454 F. 2d 1387 (Ct.
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Petitioners, residents of Washington, were present in a foreign country for more than the requisite 18 months (sec. 911(a)(2), I.R.C. 1954) while husband served in the U.S. Navy. They excluded half of his Navy salary in 1965 and 1966 and such exclusions were disallowed by the Commissioner. Court of Claims has held that the determination for 1965 was not unconstitutional, Fink v. United States, 454 F. 2d 1387 (Ct. Cl. 1972), certiorari denied 409 U.S. 844 (1972). As to 1966 petitioners now argue that disallowance is unconstitutional because, (1) it constitutes a violation of the uniformity of…
1Opinion of the Court
Edward R. Fink and Joan O. Fink, Petitioners v. Commissioner of Internal Revenue, Respondent
Fink v. Commissioner
Docket No. 619-71
United States Tax Court
60 T.C. 867; 1973 U.S. Tax Ct. LEXIS 62; 60 T.C. No. 92;
September 10, 1973, Filed
Decision will be entered for the respondent.
Petitioners, residents of Washington, were present in a foreign country for more than the requisite 18 months (sec. 911(a)(2), I.R.C. 1954) while husband served in the U.S. Navy. They excluded half of his Navy salary in 1965 and 1966 and such exclusions were disallowed by the Commissioner. Court of Claims has held that…
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