Tow v. Commissioner
United States Tax Court
Held, in determining under section 871(a)(2)(A) or (B) of the Internal Revenue Code of 1954 the number of days that petitioner, a nonresident alien, was present in the United States on two different periods of time during the calendar year 1954, the days of his arrival in the United States are to be excluded in making the computation of time, and the days of his departure from the United States are to be included in making such computation.
1Opinion of the Court
Martin Tow, Petitioner, v. Commissioner of Internal Revenue, Respondent
Tow v. Commissioner
Docket No. 86406
United States Tax Court
36 T.C. 861; 1961 U.S. Tax Ct. LEXIS 94;
August 18, 1961, Filed
Decision will be entered under Rule 50.
Held, in determining under section 871(a)(2)(A) or (B) of the Internal Revenue Code of 1954 the number of days that petitioner, a nonresident alien, was present in the United States on two different periods of time during the calendar year 1954, the days of his arrival in the United States are to be excluded in making the computation of time, and the days of his…
2Cases cited6 opinions
- Sheets v. Selden's LesseeSupreme Court of the United States · 1865
- Taylor v. BrownSupreme Court of the United States · 1893
- Weir v. CommissionerUnited States Tax Court · 1948
- Fogel v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
- Hooper v. CommissionerUnited States Board of Tax Appeals · 1932
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