Parsons v. Commissioner
United States Tax Court
Held, that a wife who is a member of a Philippine conjugal partnership and who is an American citizen domiciled in the Philippines has such interests under Philippine law in the property of such partnership as to make one-half of the income becoming the capital of the partnership taxable to her under the Internal Revenue Code of the United States.
1Opinion of the Court
These proceedings involve deficiencies in petitioner’s income tax for 1955, 1956, 1958, and 1959 in the respective amounts of $61,035.68, $90,825.54, $317,970.37, and $106,081.18. The petition alleges that respondent erred in determining such deficiencies in the income tax liability of petitioner who was a citizen of the United States, a resident of the Eepublic of the Philippines, and a member of a Philippine conjugal partnership during the taxable years in that no part of the income of the Philippine conjugal partnership from sources outside of the United States is taxable to petitioner,…
2Cases cited15 opinions
- Poe v. SeabornSupreme Court of the United States · 1930
- Helvering v. StuartSupreme Court of the United States · 1942
- Burnet v. WellsSupreme Court of the United States · 1933
- Marsman v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
- Marsman v. CommissionerUnited States Tax Court · 1952
10 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Reese v. CommissionerUnited States Tax Court · 1975
- Solano v. CommissionerUnited States Tax Court · 1974
- Grimm v. CommissionerUnited States Tax Court · 1987
- Grimm v. CommissionerUnited States Tax Court · 1987
- Parsons v. CommissionerUnited States Tax Court · 1964
4 more not listed; retrieve them via the Exa API.