De Amodio v. Commissioner
United States Tax Court
1. Petitioner John Amodio, a nonresident alien residing in Switzerland, purchased income-producing real property in the United States and managed it through real estate agents who collected rents, arranged for repairs, paid taxes, and negotiated leases. Held: a. Petitioner was engaged in business in the United States, following Jan Casimir Lewenhaupt, 20 T.C. 151 (1953). b.
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1. Petitioner John Amodio, a nonresident alien residing in Switzerland, purchased income-producing real property in the United States and managed it through real estate agents who collected rents, arranged for repairs, paid taxes, and negotiated leases. Held: a. Petitioner was engaged in business in the United States, following Jan Casimir Lewenhaupt, 20 T.C. 151 (1953). b. Petitioner did not have a "permanent establishment" in the United States within the meaning of the United States-Swiss tax convention and is taxable on dividend and interest income at rates fixed thereunder. 2. Held,…
1Opinion of the Court
Inez de Amodio, Petitioner, v. Commissioner of Internal Revenue, Respondent. John Amodio, Petitioner, v. Commissioner of Internal Revenue, Respondent
De Amodio v. Commissioner
Docket Nos. 74211, 74297
United States Tax Court
34 T.C. 894; 1960 U.S. Tax Ct. LEXIS 88;
August 22, 1960, Filed
Decision will be entered for the respondent in Docket No. 74211.
Decision will be entered under Rule 50 in Docket No. 74297.
1. Petitioner John Amodio, a nonresident alien residing in Switzerland, purchased income-producing real property in the United States and managed it through real estate agents who collected…
2Cases cited9 opinions
- Fackler v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1943
- Pinchot v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1940
- Lewenhaupt v. CommissionerUnited States Tax Court · 1953
- De Amodio v. CommissionerUnited States Tax Court · 1960
- Jan Casimir Lewenhaupt v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
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