Filler v. Commissioner
United States Tax Court
T, a U.S. citizen residing in France, spent 5 business days in the United States during each of the years 1972 and 1973, and received compensation from his employer for services performed here in the amounts of $ 1,108 and $ 1,157, respectively. In computing the foreign tax credit under secs. 901 and 904, I.R.C. 1954, the Commissioner treated these amounts as U.S. source income (sec. 861(a)(3)), the net effect being to subject such income to U.S. income tax.
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T, a U.S. citizen residing in France, spent 5 business days in the United States during each of the years 1972 and 1973, and received compensation from his employer for services performed here in the amounts of $ 1,108 and $ 1,157, respectively. In computing the foreign tax credit under secs. 901 and 904, I.R.C. 1954, the Commissioner treated these amounts as U.S. source income (sec. 861(a)(3)), the net effect being to subject such income to U.S. income tax. The French authorities taxed T upon his entire compensation for each of the years without exclusion of these amounts. Held: This Court…
1Opinion of the Court
Herbert A. Filler and Ingeborg J. Filler, Petitioners v. Commissioner of Internal Revenue, Respondent
Filler v. Commissioner
Docket No. 8767-76
United States Tax Court
74 T.C. 406; 1980 U.S. Tax Ct. LEXIS 128;
May 27, 1980, Filed
Decision will be entered for the respondent.
T, a U.S. citizen residing in France, spent 5 business days in the United States during each of the years 1972 and 1973, and received compensation from his employer for services performed here in the amounts of $ 1,108 and $ 1,157, respectively. In computing the foreign tax credit under secs. 901 and 904, I.R.C. 1954, the…
2Cases cited6 opinions
- Perkins v. CommissionerUnited States Tax Court · 1963
- Filler v. CommissionerUnited States Tax Court · 1980
- Erie Railroad v. United StatesUnited States Court of Claims · 1957
- Schering Corp. v. CommissionerUnited States Tax Court · 1978
- Crerar v. CommissionerUnited States Tax Court · 1956
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