ALEXANDER v. COMMISSIONER
United States Tax Court
Held: amount of deductions allowable under section 162 determined. Held,further: amount of exclusion from income tax under section 911 determined: petitioner did not prove that he was a bona fide resident of a foreign country or that capital was not a material income-producing factor; further, amount of deductions excluded from section 162 under section 911(a) is determined from gross income, not net income, Brewster v. Commissioner,67 T.C. 352 (1976), followed.
Read the full summary
Held: amount of deductions allowable under section 162 determined. Held,further: amount of exclusion from income tax under section 911 determined: petitioner did not prove that he was a bona fide resident of a foreign country or that capital was not a material income-producing factor; further, amount of deductions excluded from section 162 under section 911(a) is determined from gross income, not net income, Brewster v. Commissioner,67 T.C. 352 (1976), followed. Held,further, negligence penalty is not warranted for 1968 but warranted for 1969.
1Opinion of the Court
WILLIAM D. ALEXANDER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ALEXANDER v. COMMISSIONER
Docket No. 5691-73.
United States Tax Court
T.C. Memo 1978-487; 1978 Tax Ct. Memo LEXIS 28; 37 T.C.M. (CCH) 1849-75;
December 7, 1978, Filed
Held: amount of deductions allowable under section 162 determined. Held,further: amount of exclusion from income tax under section 911 determined: petitioner did not prove that he was a bona fide resident of a foreign country or that capital was not a material income-producing factor; further, amount of deductions excluded from section 162 under section…
2Cases cited22 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Cupp v. CommissionerUnited States Tax Court · 1975
- Stone v. CommissionerUnited States Tax Court · 1954
17 more not listed; retrieve them via the Exa API.