Bell v. Commissioner
United States Tax Court
Petitioner, a citizen of the United States, was employed by the Territorial Government of American Samoa during the taxable years 1952 and 1953. Held, that the Government of American Samoa was an "agency" of the United States within the meaning of section 251 (j), I. R. C. 1939, and the amounts received by him as compensation for services performed for such Government are not exempt from taxation. Edward L. Davis, 30 T. C. 462, followed.
1Opinion of the Court
The Commissioner has determined deficiencies in petitioner’s income tax for the years 1952 and 1953 in the respective amounts of $2,594.40 and $1,038.30. The deficiency for each of the taxable years is due to the determination by the Commissioner as stated in his deficiency notice:
The salaries paid to United States citizens for work performed in American Samoa are not exempt from taxation under the provisions of section 251 of the Internal Revenue Code.
To this determination of the Commissioner, petitioner alleges error as follows:
That the Commissioner of Internal Revenue erred in reversing…
2Cases cited1 opinion
- Davis v. CommissionerUnited States Tax Court · 1958
3Cited by7 opinions
- McComish v. CommissionerUnited States Tax Court · 1975
- Guardian Industries Corp. v. CommissionerUnited States Tax Court · 2014
- Bell v. CommissionerUnited States Tax Court · 1958
- Bell v. CommissionerUnited States Tax Court · 1959
- Butchart v. United StatesUnited States Court of Claims · 1960
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