McCurnin v. Commissioner
United States Tax Court
Held, petitioner, a supervising brick mason, who lived in Iran for some 22 months in barracks provided by his employer, whose wife and children remained behind in the United States, and whose right to remain in Iran was limited first by a visa, and then by a "residence permit," was not a bona fide resident of Iran within the meaning of section 116 (a), I. R. C. 1939.
1Opinion of the Court
Respondent determined a deficiency in petitioner’s income tax for tlie year 1950 in the amount of $1,183.37. At issue is whether petitioner was a bona fide resident of Iran during that year.
FINDINGS OP PACT.
Petitioner, Joseph A. McCurnin, was born in Bayonne, New Jersey, on June 9,1906. Throughout his life he has been a citizen of the United States. During most of his life, whenever petitioner has been in the United States, he has made his home in Louisiana.
Petitioner’s income tax return for the calendar year 1950 sets forth “Staff Quarters 69/2,” Abadan, Iran, as his home address. The return…
2Cases cited8 opinions
- Downs v. CommissionerUnited States Tax Court · 1946
- Downs v. COMMISSIONER OF INTERNAL REVENUE.Court of Appeals for the Ninth Circuit · 1948
- Swenson v. ThomasCourt of Appeals for the Fifth Circuit · 1947
- Jones, Collector of Internal Revenue v. KyleCourt of Appeals for the Tenth Circuit · 1951
- Thorsell v. CommissionerUnited States Tax Court · 1949
3 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Dawson v. CommissionerUnited States Tax Court · 1972
- Sochurek v. CommissionerUnited States Tax Court · 1961
- Jellinek v. CommissionerUnited States Tax Court · 1961
- Ferrer v. CommissionerUnited States Tax Court · 1968
- Matthew v. CommissionerUnited States Tax Court · 1962
10 more not listed; retrieve them via the Exa API.