Bebb v. Commissioner
United States Tax Court
Held, presence on a foreign flag vessel does not constitute presence in a foreign country or countries within the meaning of section 911(a)(2) of the 1954 Code. Held, further, petitioner's failure to file timely 1954 return was not due to reasonable cause.
1Opinion of the Court
Train, Judge:
Respondent determined deficiencies in the petitioner’s income tax and additions to tax for the calendar years 1954 and 1955 as follows:
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The issues for decision are:(1) Whether petitioner is entitled to exclude income earned between January 18,1954, and October 1,1955, inclusive, under section 911(a) (2) 1 of the Internal Revenue Code of 1954;2 and(2) Whether petitioner is liable for additions to tax under section 6651(a) of the Internal Revenue Code of 1954.3
FINDINGS OF FACT.
Some of the facts have been stipulated and are hereby found as stipulated.
The petitioner,…
2Cases cited2 opinions
- Downs v. COMMISSIONER OF INTERNAL REVENUE.Court of Appeals for the Ninth Circuit · 1948
- Souza v. CommissionerUnited States Tax Court · 1960
3Cited by58 opinions
- Davis v. CommissionerUnited States Tax Court · 1983
- Conlorez Corp. v. CommissionerUnited States Tax Court · 1968
- Richardson v. CommissionerUnited States Tax Court · 1979
- Elliott v. CommissionerUnited States Tax Court · 1988
- Estate of Johnson v. CommissionerUnited States Tax Court · 1987
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