Salmon v. Commissioner
United States Tax Court
Nonresident -- Section 116 (a), I. R. C. -- Exclusion from Income. -- A citizen, who for many years resided in the Philippines and carried on a business there throughout the taxable year, and who was not physically present in the United States for as much as one-half of the year, was a nonresident for the purpose of section 116 (a).
1Opinion of the Court
Charles Schofield Salmon, Petitioner, v. Commissioner of Internal Revenue, Respondent
Salmon v. Commissioner
Docket No. 7515
United States Tax Court
12 T.C. 40; 1949 U.S. Tax Ct. LEXIS 295;
January 26, 1949, Promulgated
Decision will be entered under Rule 50.
Nonresident -- Section 116 (a), I. R. C. -- Exclusion from Income. -- A citizen, who for many years resided in the Philippines and carried on a business there throughout the taxable year, and who was not physically present in the United States for as much as one-half of the year, was a nonresident for the purpose of section 116 (a).
E. J. Botts,…
2Cases cited3 opinions
- Swent v. CommissionerUnited States Tax Court · 1945
- Fichter v. CommissionerUnited States Tax Court · 1947
- Salmon v. CommissionerUnited States Tax Court · 1949