Constantinescu v. Commissioner
United States Tax Court
Under the facts, held, petitioner, who was an alien physically present in the United States, was not a resident of the United States within the meaning of Treasury regulations and applicable decisions during the year 1944 and the period January 1 to November 3, 1945.
1Opinion of the Court
OPINION.
Black, Judge-.
The Commissioner has determined deficiencies in petitioner’s income tax of $3,346.15 for the calendar year 1944 and $1,851.79 for the period January 1 to October 31,1945. The deficiency for the year 1944 is due to four items being included in petitioner’s net income, namely:(a) Dividends_$2,650.00(b) Interest_ 500.00(c) Short term capital gain_ 3,983. 74(d) Long term capital gain-_- 6,694.83
Those items are explained in the deficiency notice as follows:(a), (b), (c) and (d) An examination of the records discloses that you received the items of income shown below. Since no…
2Cases cited4 opinions
- Heiner v. DonnanSupreme Court of the United States · 1932
- Johnson v. CommissionerUnited States Tax Court · 1946
- Downs v. CommissionerUnited States Tax Court · 1946
- Baer v. CommissionerUnited States Tax Court · 1946
3Cited by15 opinions
- Brittingham v. CommissionerUnited States Tax Court · 1976
- Schoneberger v. CommissionerUnited States Tax Court · 1980
- Jellinek v. CommissionerUnited States Tax Court · 1961
- Park v. CommissionerUnited States Tax Court · 1982
- Garzon v. United StatesDistrict Court, S.D. Florida · 1985
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