Legal Opinion

Liljeberg v. Comm'r

United States Tax Court

Decided March 16, 2017No. Docket Nos. 20796-14, 22042-14, 23061-14Published

Ps are nonresident aliens. In 2012 they were full-time students at foreign universities when they participated in the U.S. Department of State Summer Work Travel Program (SWTP). They came to the United States for no more than four months over the summer to participate in cultural exchange, travel domestically, and work in temporary or seasonal jobs.

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Ps are nonresident aliens. In 2012 they were full-time students at foreign universities when they participated in the U.S. Department of State Summer Work Travel Program (SWTP). They came to the United States for no more than four months over the summer to participate in cultural exchange, travel domestically, and work in temporary or seasonal jobs. Ps sought to deduct expenses they paid in connection with the SWTP, including the costs of airfare, program and visa fees, travel health insurance, and meals and entertainment. R denied Ps' claimed deductions, though he has since conceded the…

1Opinion of the Court

RICHARD LILJEBERG, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Liljeberg v. Comm'r

Docket Nos. 20796-14, 22042-14, 23061-14.

United States Tax Court

2017 U.S. Tax Ct. LEXIS 7; 148 T.C. No. 6;

March 16, 2017, Filed

Decisions will be entered under Rule 155.

Ps are nonresident aliens. In 2012 they were full-time students at foreign universities when they participated in the U.S. Department of State Summer Work Travel Program (SWTP). They came to the United States for no more than four months over the summer to participate in cultural exchange, travel domestically, and work in…

2Cases cited28 opinions

  1. Commissioner v. FlowersSupreme Court of the United States · 1946
  2. Peurifoy v. CommissionerSupreme Court of the United States · 1958
  3. Kroll v. CommissionerUnited States Tax Court · 1968
  4. Primuth v. CommissionerUnited States Tax Court · 1970
  5. Tucker v. CommissionerUnited States Tax Court · 1971

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