Sjoroos v. Commissioner
United States Tax Court
Held, that sec. 912(2), I.R.C. 1954, granting Federal employees stationed in Alaska exemption from Federal income taxes on their cost-of-living allowances, does not deprive individuals employed in the private sector of their constitutional right to equal protection of the laws.
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Held, that sec. 912(2), I.R.C. 1954, granting Federal employees stationed in Alaska exemption from Federal income taxes on their cost-of-living allowances, does not deprive individuals employed in the private sector of their constitutional right to equal protection of the laws. Held, further, that petitioners have not shown that part of their underpayment of tax was not due to negligence or intentional disregard of the revenue laws within the meaning of sec. 6653(a), I.R.C. 1954.
1Opinion of the Court
Featherston, Judge:
Respondent determined a deficiency in petitioners’ Federal income tax for 1979 in the amount of $5,022, and an addition to tax under section 6653(a)1 in the amount of $251. Other matters having been resolved by agreement of the parties, the only issues remaining for decision are:(1) Whether the Federal income tax exemption provided for in section 912(2) for certain cost-of-living allowances received by Federal employees violates petitioners’ constitutional guarantee of equal protection of the laws; and(2) Whether any part of any underpayment of tax for 1979 was due to…
2Cases cited9 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Dandridge v. WilliamsSupreme Court of the United States · 1970
- Bolling v. SharpeSupreme Court of the United States · 1954
- Skinner v. Oklahoma Ex Rel. WilliamsonSupreme Court of the United States · 1942
- United States v. Maryland Savings-Share Ins. Corp.Supreme Court of the United States · 1970
4 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Carl Albert Grauvogel v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
- Smith v. CommissionerUnited States Tax Court · 1984
- Lyman v. CommissionerUnited States Tax Court · 1984
- Grauvogel v. CommissionerUnited States Tax Court · 1984
- Haggerty v. CommissionerUnited States Tax Court · 1985
3 more not listed; retrieve them via the Exa API.