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