Legal Opinion

Simenon v. Commissioner

United States Tax Court

Decided September 29, 1965No. Docket No. 86040Published

Petitioner is a citizen of Belgium. He is a professional writer who earns his living by writing fiction and granting various rights to others in his literary works in return for royalties. He entered the United States under a permanent visa in 1947 and maintained a residence here thereafter. He carried on a business in the United States as an author.

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Petitioner is a citizen of Belgium. He is a professional writer who earns his living by writing fiction and granting various rights to others in his literary works in return for royalties. He entered the United States under a permanent visa in 1947 and maintained a residence here thereafter. He carried on a business in the United States as an author. He went to Europe with his family on March 19, 1955; he lived in France until June 20, 1956, and then lived in Switzerland thereafter. He received author's royalties from U.S. sources in 1955 after March 20, which he claims were exempt from the…

1Opinion of the Court

Georges Simenon, Petitioner, v. Commissioner of Internal Revenue, Respondent

Simenon v. Commissioner

Docket No. 86040

United States Tax Court

44 T.C. 820; 1965 U.S. Tax Ct. LEXIS 31;

September 29, 1965, Filed

Decision will be entered for the respondent.

Petitioner is a citizen of Belgium. He is a professional writer who earns his living by writing fiction and granting various rights to others in his literary works in return for royalties. He entered the United States under a permanent visa in 1947 and maintained a residence here thereafter. He carried on a business in the United States as an author.…

2Cases cited45 opinions

  1. Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
  2. Higgins v. CommissionerSupreme Court of the United States · 1941
  3. Brewster v. GageSupreme Court of the United States · 1930
  4. Helvering v. Wilshire Oil Co.Supreme Court of the United States · 1939
  5. Commissioner v. Scottish American Investment Co.Supreme Court of the United States · 1945

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