Acone v. Comm'r
United States Tax Court
P-H flew airplanes for a South Korean airline company in 2011 and 2012, but he spent only about a third of each year in South Korea and more than 40% of each year in the United States. P-H returned to his home in the United States frequently during those years and spent most of his days off in the United States, where his wife and house remained. He stayed in South Korea only when work required it, and stayed in the United States whenever he could.
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P-H flew airplanes for a South Korean airline company in 2011 and 2012, but he spent only about a third of each year in South Korea and more than 40% of each year in the United States. P-H returned to his home in the United States frequently during those years and spent most of his days off in the United States, where his wife and house remained. He stayed in South Korea only when work required it, and stayed in the United States whenever he could. When P-H stayed in South Korea, he always stayed in the same hotel, provided to him at no cost by the airline, but stayed in various rooms in that…
1Opinion of the Court
GREGORY L. ACONE AND JUDITH E. FINN ACONE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Acone v. Comm'r
Docket No. 7632-15.
United States Tax Court
T.C. Memo 2017-162; 2017 Tax Ct. Memo LEXIS 162; 114 T.C.M. (CCH) 219;
August 22, 2017, Filed
An appropriate decision will be entered.
P-H flew airplanes for a South Korean airline company in 2011 and 2012, but he spent only about a third of each year in South Korea and more than 40% of each year in the United States. P-H returned to his home in the United States frequently during those years and spent most of his days off in the United…
2Cases cited10 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Howard J. Sochurek v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1962
- John T. Lemay and Yvonne P. Lemay v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Schoneberger v. CommissionerUnited States Tax Court · 1980
- Vento v. Director of Virgin Islands Bureau of Internal RevenueCourt of Appeals for the Third Circuit · 2013
5 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Hudson v. Comm'rUnited States Tax Court · 2017
- Andrew Rush Wentworth v. CommissionerUnited States Tax Court · 2018
- Douglas H. Cutting v. CommissionerUnited States Tax Court · 2020
- Joseph S. Bellwood & Jacqueline E. Bellwood v. CommissionerUnited States Tax Court · 2019