Harrison v. Commissioner
United States Tax Court
P, a citizen of the Federal Republic of Germany and a resident alien of the United States, was employed in the United States by the Federal Republic of Germany, Office of Defense Administration, U.S.A. and Canada and received wages during 2006-08. P claims her wages were exempt from U.S. taxation under I.R.C. sec. 893(a) and the Agreement Between the Parties to the North Atlantic Treaty Regarding the Status of Their Forces (NATO SOFA), June 19, 1951, 4 U.S.T. 1792. Held: P's…
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P, a citizen of the Federal Republic of Germany and a resident alien of the United States, was employed in the United States by the Federal Republic of Germany, Office of Defense Administration, U.S.A. and Canada and received wages during 2006-08. P claims her wages were exempt from U.S. taxation under I.R.C. sec. 893(a) and the Agreement Between the Parties to the North Atlantic Treaty Regarding the Status of Their Forces (NATO SOFA), June 19, 1951, 4 U.S.T. 1792. Held: P's wages are not exempt from taxation under I.R.C. sec. 893(a). Held, further, P does not benefit from the provisions of…
1Opinion of the Court
Marvel, Judge-.
Respondent determined deficiencies in petitioner’s Federal income taxes of $18,637, $18,904, and $31,924 for 2006, 2007, and 2008, respectively, and an addition to tax under section 6651(a)(1) 1 of $7,846 for 2008. After a concession, 2 the sole issue for decision is whether petitioner’s wages paid by the Federal Republic of Germany (Germany), Office of Defense Administration, U.S.A. and Canada (German Defense Administration) are exempt from taxation under section 893(a) or the Agreement Between the Parties to the North Atlantic Treaty Regarding the Status of Their Forces (NATO…
2Cases cited7 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Sunday Lake Iron Co. v. Township of WakefieldSupreme Court of the United States · 1918
- Davis v. CommissionerUnited States Tax Court · 1976
- Knudsen v. Comm'rUnited States Tax Court · 2008
- Rose v. CommissionerUnited States Tax Court · 1970
2 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
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- Clifford A. Abrahamsen & Sole K. Abrahamsen v. CommissionerUnited States Tax Court · 2014
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