McComish v. Commissioner
United States Tax Court
T, a United States citizen, was employed by the government of the Trust Territory of the Pacific Islands where he lived during such employment. Held, the government of the Trust Territory of the Pacific Islands is an "agency" of the United States as intended by sec. 911(a)(2), I.R.C. 1954, and the amounts which it paid to T are therefore not excludable from T's gross income under that Code section.
1Opinion of the Court
John D. McComish and Genevieve A. McComish, Petitioners v. Commissioner of Internal Revenue, Respondent
McComish v. Commissioner
Docket No. 4751-71
United States Tax Court
64 T.C. 909; 1975 U.S. Tax Ct. LEXIS 82;
August 19, 1975, Filed
Decision will be entered under Rule 155.
T, a United States citizen, was employed by the government of the Trust Territory of the Pacific Islands where he lived during such employment. Held, the government of the Trust Territory of the Pacific Islands is an "agency" of the United States as intended by sec. 911(a)(2), I.R.C. 1954, and the amounts which it paid to T are…
2Cases cited22 opinions
- Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
- Standard Oil Co. of Cal. v. JohnsonSupreme Court of the United States · 1942
- Helvering v. Morgan's, Inc.Supreme Court of the United States · 1934
- Porter v. United StatesUnited States Court of Claims · 1974
- The People Of Saipan v. United States Department Of InteriorCourt of Appeals for the Ninth Circuit · 1974
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