Fichter v. Commissioner
United States Tax Court
From 1919 until in August 1941, petitioner was the manager of the Osaka, Japan, branch of an American industrial concern. It is stipulated that he was a resident of Japan for 22 years up until January 1, 1941. In the early part of 1941 petitioner came to the United States to confer with his firm concerning the threatening international situation. Before returning to Japan he visited his children, who were being educated in Canada.
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From 1919 until in August 1941, petitioner was the manager of the Osaka, Japan, branch of an American industrial concern. It is stipulated that he was a resident of Japan for 22 years up until January 1, 1941. In the early part of 1941 petitioner came to the United States to confer with his firm concerning the threatening international situation. Before returning to Japan he visited his children, who were being educated in Canada. After returning to Japan he found the situation worsened and decided to leave that country. He left August 1, 1941, and arrived in this country August 28. During…
1Opinion of the Court
Paul J. Fichter, Petitioner, v. Commissioner of Internal Revenue, Respondent
Fichter v. Commissioner
Docket No. 7877
United States Tax Court
9 T.C. 1126; 1947 U.S. Tax Ct. LEXIS 13;
December 16, 1947, Promulgated
Decision will be entered for the petitioner.
From 1919 until in August 1941, petitioner was the manager of the Osaka, Japan, branch of an American industrial concern. It is stipulated that he was a resident of Japan for 22 years up until January 1, 1941. In the early part of 1941 petitioner came to the United States to confer with his firm concerning the threatening international situation.…
2Cases cited2 opinions
- Swent v. CommissionerUnited States Tax Court · 1945
- Fichter v. CommissionerUnited States Tax Court · 1947