Legal Opinion

Furstenberg v. Commissioner

United States Tax Court

Decided November 26, 1984No. Docket No. 19977-80Published

From Jan. 1, 1975, to Dec. 22, 1975, petitioner was a U.S. citizen. On Dec. 23, 1975, petitioner adopted Austrian citizenship, thereby losing her U.S. citizenship. During 1975, petitioner received distributions from two complex trusts of which she was a beneficiary.

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From Jan. 1, 1975, to Dec. 22, 1975, petitioner was a U.S. citizen. On Dec. 23, 1975, petitioner adopted Austrian citizenship, thereby losing her U.S. citizenship. During 1975, petitioner received distributions from two complex trusts of which she was a beneficiary. Held, petitioner did not have tax avoidance as one of her principal purposes in expatriating; thus her income is not taxable under sec. 877, I.R.C. 1954. Held, further, petitioner is taxable at the graduated rates applicable to U.S. citizens on an accumulation distribution from a complex testamentary trust received by her before…

1Opinion of the Court

Cecil B. Furstenberg, Petitioner v. Commissioner of Internal Revenue, Respondent

Furstenberg v. Commissioner

Docket No. 19977-80

United States Tax Court

83 T.C. 755; 1984 U.S. Tax Ct. LEXIS 12; 83 T.C. No. 43;

November 26, 1984. November 26, 1984, Filed

Decision will be entered under Rule 155.

From Jan. 1, 1975, to Dec. 22, 1975, petitioner was a U.S. citizen. On Dec. 23, 1975, petitioner adopted Austrian citizenship, thereby losing her U.S. citizenship. During 1975, petitioner received distributions from two complex trusts of which she was a beneficiary.

Held, petitioner did not have tax avoidance…

2Cases cited26 opinions

  1. Malat v. RiddellSupreme Court of the United States · 1966
  2. Commissioner v. LoBueSupreme Court of the United States · 1956
  3. Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
  4. Achiro v. CommissionerUnited States Tax Court · 1981
  5. Cook v. TaitSupreme Court of the United States · 1924

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