Baehre v. Commissioner
United States Tax Court
On or about August 23, 1942, petitioner, a United States citizen, left this country for Canada in pursuance of his employment concerning a war contract. About 10 days after his arrival in Canada petitioner moved out of his hotel room and arranged for the arrival of his family.
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On or about August 23, 1942, petitioner, a United States citizen, left this country for Canada in pursuance of his employment concerning a war contract. About 10 days after his arrival in Canada petitioner moved out of his hotel room and arranged for the arrival of his family. Petitioner's family, his wife and two children, went to Canada in September 1942, with all of petitioner's possessions, including furniture and automobile, with intent to reside there for an indefinite period. Petitioner and his family lived in an apartment in Edmonton, Canada, until October 1, 1944, at which time…
1Opinion of the Court
OPINION.
Black, Judge:
The only question in this proceeding is whether the compensation which petitioner received during the years 1942, 1943, and 1944 for services rendered in the Dominion of Canada is includible in his taxable income within the meaning of sections 116 (a) (1) and (2) of the Internal Revenue Code as amended by section 148 (a) of the Revenue Act of 1942.1
Petitioner contends that in accordance with the provisions of section 116 (a) (1) compensation received in 1943 for services rendered in Canada is to be excluded from gross income because petitioner was a bona fide resident of…
2Cases cited3 opinions
- Johnson v. CommissionerUnited States Tax Court · 1946
- Downs v. CommissionerUnited States Tax Court · 1946
- Bouldin v. CommissionerUnited States Tax Court · 1947
3Cited by44 opinions
- Howard J. Sochurek v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1962
- Nelson v. CommissionerUnited States Tax Court · 1958
- Brittingham v. CommissionerUnited States Tax Court · 1976
- Friedman v. CommissionerUnited States Tax Court · 1961
- Sochurek v. CommissionerUnited States Tax Court · 1961
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