Huff v. Commissioner
United States Tax Court
Claiming to be a bona fide resident of the U.S.Virgin Islands (the Virgin Islands) during 2002, 2003, and 2004, and claiming he was qualified for the gross income tax exclusion provided by I.R.C. sec. 932(c)(4), P, a U.S. citizen, filed territorial income tax returns with, and paid income tax to, the Virgin Islands. He did not file Federal income tax returns or pay Federal income tax for those years.
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Claiming to be a bona fide resident of the U.S.Virgin Islands (the Virgin Islands) during 2002, 2003, and 2004, and claiming he was qualified for the gross income tax exclusion provided by I.R.C. sec. 932(c)(4), P, a U.S. citizen, filed territorial income tax returns with, and paid income tax to, the Virgin Islands. He did not file Federal income tax returns or pay Federal income tax for those years. R determined that P was not a bona fide resident of the Virgin Islands and was not qualified for the gross income tax exclusion as claimed. P moves to interplead the Virgin Islands in this…
1Opinion of the Court
OPINION
JACOBS, Judge:
This matter is before the Court on petitioner’s motion to interplead the Government of the U.S. Virgin Islands (Virgin Islands) in this proceeding. For the reasons set forth infra, we shall deny petitioner’s motion.
Background
I. Procedural Background
The basic facts in this case are set forth in Huff v. Commissioner, 135 T.C. 222 (2010). We thus recite only those facts required to resolve the motion before us.
Petitioner is a U.S. citizen who claims he was a bona fide resident of the Virgin Islands during 2002, 2003, and 2004. Petitioner filed territorial income tax returns…
2Cases cited9 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Metropolitan Life Insurance v. PriceCourt of Appeals for the Third Circuit · 2007
- Breman v. CommissionerUnited States Tax Court · 1976
- Prudential Insurance Co. of America v. HovisCourt of Appeals for the Third Circuit · 2009
- Intermountain Insurance Service of Vail, Ltd. Liability Co. v. CommissionerUnited States Tax Court · 2010
4 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Huff v. CommissionerUnited States Tax Court · 2012
- Appleton v. Comm'rUnited States Tax Court · 2013
- Arthur I. Appleton, Jr. , and The Government of the United States Virgin Islands, Intervenor v. CommissionerUnited States Tax Court · 2013
- Appleton v. Comm'rUnited States Tax Court · 2013
- Arthur I. Appleton, Jr. , and The Government of the United States Virgin Islands, Intervenor v. CommissionerUnited States Tax Court · 2013