Adams v. Commissioner
United States Tax Court
Petitioner William, a Canadian citizen, spent about 70 days of each of the years 1957 through 1959 in Florida in a furnished house purchased in 1953 and owned with his wife as a tenant by the entireties. Petitioner Hazel spent 9 to 10 months during each of the 3 years in the house with their children, who attended Florida schools. They spent the remainder of these years in a house in Canada occupied by them for many years, title to which was in Hazel's name.
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Petitioner William, a Canadian citizen, spent about 70 days of each of the years 1957 through 1959 in Florida in a furnished house purchased in 1953 and owned with his wife as a tenant by the entireties. Petitioner Hazel spent 9 to 10 months during each of the 3 years in the house with their children, who attended Florida schools. They spent the remainder of these years in a house in Canada occupied by them for many years, title to which was in Hazel's name. Both made sworn statements to United States and Florida officials that they intended to become United States residents. Held, William…
1Opinion of the Court
William E. Adams and Hazel M. Adams, Petitioners, v. Commissioner of Internal Revenue, Respondent
Adams v. Commissioner
Docket No. 6017-64
United States Tax Court
46 T.C. 352; 1966 U.S. Tax Ct. LEXIS 89;
June 14, 1966, Filed
Decision will be entered under Rule 50.
Petitioner William, a Canadian citizen, spent about 70 days of each of the years 1957 through 1959 in Florida in a furnished house purchased in 1953 and owned with his wife as a tenant by the entireties. Petitioner Hazel spent 9 to 10 months during each of the 3 years in the house with their children, who attended Florida schools. They…
2Cases cited21 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Glenn Weible and Patricia Weible v. United StatesCourt of Appeals for the Ninth Circuit · 1957
- Robert A. Henningsen, and Cross and R.A. And Margaret Henningsen v. Commissioner of Internal Revenue, AndCourt of Appeals for the Fourth Circuit · 1957
- Marsman v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
- Adams v. CommissionerUnited States Tax Court · 1966
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