Legal Opinion

Hack v. Commissioner

United States Tax Court

Decided March 31, 1960No. Docket No. 65335PublishedCited by 8 opinions

Held, on the facts, petitioner was a bona fide resident of a foreign country or countries during the period in question, within the meaning of section 116(a)(1) of the Internal Revenue Code of 1939.

1Opinion of the Court

Forrester, Judge:

The respondent determined deficiencies in the income tax of petitioners, and additions thereto for failure to make and file returns under section 291(a) of the Internal Revenue Code of 1939, as follows:

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Respondent has conceded on brief that the foregoing section 291(a) additions are improper, thus the sole issue remaining is whether during each of the taxable years in question petitioner was a bona fide resident of a foreign country or countries within the meaning of section 116(a) (1) of the Internal Revenue Code of 1939.1 Petitioner has raised as an alternative…

2Cases cited2 opinions

  1. Nelson v. CommissionerUnited States Tax Court · 1958
  2. McCurnin v. CommissionerUnited States Tax Court · 1958

3Cited by8 opinions

  1. Howard J. Sochurek v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1962
  2. Adams v. CommissionerUnited States Tax Court · 1966
  3. Sochurek v. CommissionerUnited States Tax Court · 1961
  4. Carpenter v. United StatesDistrict Court, N.D. Texas · 1972
  5. Adams v. CommissionerUnited States Tax Court · 1966

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