Craig v. Commissioner
United States Tax Court
Held, P, a bona fide resident of Switzerland since 1968, abandoned his Swiss residence on May 12, 1974, when he and his family severed all community ties, took all their possessions, and left for the United States with the definite intention of not returning. Therefore, under sec. 911, I.R.C. 1954, as amended, Ps are entitled to exclude, as earned income from sources outside the United States, $ 8,973 from their gross income for 1974.
1Opinion of the Court
Tietjens, Judge:
Respondent determined a deficiency of $3,5961 in petitioners’ Federal income tax for 1974. The sole issue for our decision is whether, for the purpose of calculating the foreign earned income exclusion under section 911,2 petitioner Raymond A. Craig abandoned Ms Swiss residence on January 27, 1974, on February 1,1974, or on May 12,1974.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation and attached exhibits are incorporated herein by reference.
At the time they filed their petition, petitioners resided at Wilmington, Del. Petitioners timely…
2Cases cited8 opinions
- Adams v. CommissionerUnited States Tax Court · 1966
- Dillin v. CommissionerUnited States Tax Court · 1971
- Friedman v. CommissionerUnited States Tax Court · 1961
- Seeley v. Commissioner of Internal Revenue. Seeley v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1951
- Baer v. CommissionerUnited States Tax Court · 1946
3 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Maclean v. CommissionerUnited States Tax Court · 1980
- Bergersen v. CommissionerUnited States Tax Court · 1995
- Riley v. CommissionerUnited States Tax Court · 1980
- Vazquez v. CommissionerUnited States Tax Court · 1993
- Craig v. CommissionerUnited States Tax Court · 1980
3 more not listed; retrieve them via the Exa API.