Vitaly Nikolaevich Baturin v. Commissioner

153 T.C. No. 10

UNITED STATES TAX COURT VITALY NIKOLAEVICH BATURIN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14796-14. Filed December 18, 2019. R issued P a notice of deficiency. P filed a petition in which he contends that his wages are exempt from taxation pursuant to Article 18 of the Convention for the Avoidance of Double Taxation between the United States and the Russian Federation. R contends that wages are by definition ineligible for the Article 18 exemption. Held: Wages may be eligible for the Article 18 exemption so long as they are payments similar to a…