Bottome v. Commissioner
United States Tax Court
T, a United States citizen, was a bona fide resident of Venezuela in the taxable years. His wife was a citizen of Venezuela and a nonresident alien of the United States. Venezuela is a community property country. T received compensation for services performed in Venezuela during the taxable years, half of which was owned by his wife. The wife was not required to report her share of the community income for Federal income tax purposes.
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T, a United States citizen, was a bona fide resident of Venezuela in the taxable years. His wife was a citizen of Venezuela and a nonresident alien of the United States. Venezuela is a community property country. T received compensation for services performed in Venezuela during the taxable years, half of which was owned by his wife. The wife was not required to report her share of the community income for Federal income tax purposes. Held, T is entitled to exclude $ 35,000 in 1964 and $ 25,000 in 1965 and 1966 as earned income from sources without the United States under sec. 911(a) and (c),…
1Opinion of the Court
Robert R. Bottome, Petitioner v. Commissioner of Internal Revenue, Respondent
Bottome v. Commissioner
Docket No. 2220-70
United States Tax Court
58 T.C. 212; 1972 U.S. Tax Ct. LEXIS 135;
May 3, 1972, Filed
Decision will be entered under Rule 50.
T, a United States citizen, was a bona fide resident of Venezuela in the taxable years. His wife was a citizen of Venezuela and a nonresident alien of the United States. Venezuela is a community property country. T received compensation for services performed in Venezuela during the taxable years, half of which was owned by his wife. The wife was not…
Also in this document: Dissent.
2Cases cited18 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Brewster v. GageSupreme Court of the United States · 1930
- Sanford v. CommissionerUnited States Tax Court · 1968
- William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
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