Miller v. Commissioner
United States Tax Court
In 1975 and 1976, petitioner received earned income from sources outside the United States. This income was the community property of petitioner and his nonresident alien wife. Petitioner deducted the full amounts of alimony and other expenses on his 1975 and 1976 Federal income tax returns.
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In 1975 and 1976, petitioner received earned income from sources outside the United States. This income was the community property of petitioner and his nonresident alien wife. Petitioner deducted the full amounts of alimony and other expenses on his 1975 and 1976 Federal income tax returns. Held, petitioner is entitled to the full amount of the exclusion under sec. 911(a) and (c)( 1)(B), I.R.C. 1954. Bottome v. Commissioner, 58 T.C. 212 (1972), affd. per curiam 486 F.2d 1314 (D.C. Cir. 1973), followed. Held, further: There are genuine issues of material fact as to whether petitioner is…
1Opinion of the Court
William Field Miller, Petitioner v. Commissioner of Internal Revenue, Respondent
Miller v. Commissioner
Docket No. 11722-79
United States Tax Court
73 T.C. 1039; 1980 U.S. Tax Ct. LEXIS 172;
March 10, 1980, Filed
In 1975 and 1976, petitioner received earned income from sources outside the United States. This income was the community property of petitioner and his nonresident alien wife. Petitioner deducted the full amounts of alimony and other expenses on his 1975 and 1976 Federal income tax returns. Held, petitioner is entitled to the full amount of the exclusion under sec. 911(a) and (c)( 1)(B),…
2Cases cited13 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Weinberg v. WeinbergCalifornia Supreme Court · 1967
- Dunn v. MullanCalifornia Supreme Court · 1931
- Wheeland v. RodgersCalifornia Supreme Court · 1942
- Jean Renoir and Dido Freire Renoir v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
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