Braddock v. Commissioner
United States Tax Court
Petitioner husband, a U.S. citizen, was employed in the United States by Intelsat, an international organization which was not subject to Federal, State, or local income or Social Security taxes. While Intelsat was not subject to FICA taxes, its U.S. employees were subject to tax on their earnings as if received from self-employment under secs. 1401 et seq., I.R.C.
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Petitioner husband, a U.S. citizen, was employed in the United States by Intelsat, an international organization which was not subject to Federal, State, or local income or Social Security taxes. While Intelsat was not subject to FICA taxes, its U.S. employees were subject to tax on their earnings as if received from self-employment under secs. 1401 et seq., I.R.C. Petitioner was compensated by Intelsat for his base salary, overtime, dependency, and transportation allowances, as well as all his Federal and District of Columbia income tax liabilities including self-employment tax. Petitioner…
1Opinion of the Court
OPINION
DAWSON, Judge:
This case was assigned to Special Trial Judge Helen A. Buckley pursuant to the provisions of section TJJSAfb)1 and Rule 180 et seq.2 The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
BUCKLEY, Special Trial Judge:
Respondent determined a deficiency in petitioners’ Federal income tax for the year 1984 in the amount of $9,988.40 together with the following additions to tax:
Sec. 6651(a) Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661
$427.37 $712.02 1 $2,497.10
After concessions by both parties, the…
2Cases cited6 opinions
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Newberry v. CommissionerUnited States Tax Court · 1981
- Driscoll v. Washington County Fire Ins.Court of Appeals for the Third Circuit · 1940
- Lemery v. CommissionerUnited States Tax Court · 1970
- Hornaday v. CommissionerUnited States Tax Court · 1983
1 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Hitchins v. CommissionerUnited States Tax Court · 1994
- Fort Howard Corp. v. CommissionerUnited States Tax Court · 1994
- Richard J. Bot Phyllis Bot v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2003
- Bot v. Comm'rUnited States Tax Court · 2002
- Estate of Monroe v. CommissionerUnited States Tax Court · 1995
16 more not listed; retrieve them via the Exa API.