Christensen v. Commissioner
United States Tax Court
Petitioners resided in Puerto Rico from 1966 through 1969. After returning to the United States, petitioners were notified that their Puerto Rican tax returns were to be the subject of an audit by the Puerto Rican Bureau of Income Tax. In connection with this audit, petitioners incurred certain legal and accounting expenses which they deducted on their 1972 and 1973 Federal income tax returns.
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Petitioners resided in Puerto Rico from 1966 through 1969. After returning to the United States, petitioners were notified that their Puerto Rican tax returns were to be the subject of an audit by the Puerto Rican Bureau of Income Tax. In connection with this audit, petitioners incurred certain legal and accounting expenses which they deducted on their 1972 and 1973 Federal income tax returns. Held, petitioners' expenses are "properly allocable to or chargeable against" income exempted by sec. 933(1), I.R.C. 1954, and, therefore, are not deductible.
1Opinion of the Court
Lauge H. and Helen S. Christensen, Petitioners v. Commissioner of Internal Revenue, Respondent
Christensen v. Commissioner
Docket No. 10113-76
United States Tax Court
71 T.C. 328; 1978 U.S. Tax Ct. LEXIS 17;
December 4, 1978, Filed
Decision will be entered for the respondent.
Petitioners resided in Puerto Rico from 1966 through 1969. After returning to the United States, petitioners were notified that their Puerto Rican tax returns were to be the subject of an audit by the Puerto Rican Bureau of Income Tax. In connection with this audit, petitioners incurred certain legal and accounting expenses…
2Cases cited7 opinions
- Anne Moen Bullitt Brewster v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1973
- Brewster v. CommissionerUnited States Tax Court · 1970
- Hughes v. CommissionerUnited States Tax Court · 1975
- Roque v. CommissionerUnited States Tax Court · 1976
- Cornman v. CommissionerUnited States Tax Court · 1975
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