Legal Opinion

Furst v. Commissioner

United States Board of Tax Appeals

Decided April 1, 1930No. Docket No. 26892Published

1. The Board has jurisdiction of a proceeding brought by a withholding agent to determine the liability of the withholding agent for the taxes of nonresident alien individuals. 2. Where nonresident alien individuals neither filed returns of all income from sources within the United States nor claims with the petitioner as withholding agent for the benefit of the personal exemption, the petitioner, as withholding agent, is not entitled, under the Revenue Act of 1924 and the…

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1. The Board has jurisdiction of a proceeding brought by a withholding agent to determine the liability of the withholding agent for the taxes of nonresident alien individuals. 2. Where nonresident alien individuals neither filed returns of all income from sources within the United States nor claims with the petitioner as withholding agent for the benefit of the personal exemption, the petitioner, as withholding agent, is not entitled, under the Revenue Act of 1924 and the regulations promulgated thereunder, to the benefit of a personal exemption for each non-resident alien individual.

1Opinion of the Court

MYRA FURST, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Furst v. Commissioner

Docket No. 26892.

United States Board of Tax Appeals

19 B.T.A. 471; 1930 BTA LEXIS 2390;

April 1, 1930, Promulgated

1. The Board has jurisdiction of a proceeding brought by a withholding agent to determine the liability of the withholding agent for the taxes of nonresident alien individuals.

2. Where nonresident alien individuals neither filed returns of all income from sources within the United States nor claims with the petitioner as withholding agent for the benefit of the personal exemption, the…

2Cases cited1 opinion

  1. Furst v. CommissionerUnited States Board of Tax Appeals · 1930

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