Cini v. Commissioner
United States Tax Court
Petitioner, a U.S. citizen residing in France, was employed by J-M Europe Corp., a Delaware corporation subsidiary of Johns-Manville Corp., as an executive overseeing the operations of various subsidiaries of Johns-Manville Corp. which were doing business in Europe. Petitioner worked part of the time within the United States and part of the time without the United States.
Read the full summary
Petitioner, a U.S. citizen residing in France, was employed by J-M Europe Corp., a Delaware corporation subsidiary of Johns-Manville Corp., as an executive overseeing the operations of various subsidiaries of Johns-Manville Corp. which were doing business in Europe. Petitioner worked part of the time within the United States and part of the time without the United States. Petitioner received from his employer as compensation for his services a basic salary and bonuses based on the earnings of the foreign subsidiaries of Johns-Manville Corp. and on the export earnings of Johns-Manville Corp.…
1Opinion of the Court
Antoine L. Cini, Petitioner v. Commissioner of Internal Revenue, Respondent; Gertrud Cini, Petitioner v. Commissioner of Internal Revenue, Respondent
Cini v. Commissioner
Docket Nos. 4962-75, 5115-75
United States Tax Court
67 T.C. 857; 1977 U.S. Tax Ct. LEXIS 146;
February 28, 1977, Filed
Decisions will be entered under Rule 155.
Petitioner, a U.S. citizen residing in France, was employed by J-M Europe Corp., a Delaware corporation subsidiary of Johns-Manville Corp., as an executive overseeing the operations of various subsidiaries of Johns-Manville Corp. which were doing business in Europe.…
2Cases cited1 opinion
- Cini v. CommissionerUnited States Tax Court · 1977