Hall v. Commissioner
United States Tax Court
P, a U.S. citizen, was a civilian employee of the U.S. Army from 1953 through Dec. 31, 1971. P's wife was a citizen of France.
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P, a U.S. citizen, was a civilian employee of the U.S. Army from 1953 through Dec. 31, 1971. P's wife was a citizen of France. The couple resided in Morocco from 1953 to 1959, in France from 1959 to 1967, and in Germany from 1967 through 1971. Held, P failed to establish that his domicile for 1970 and 1971 was other than Germany, where he lived and worked; under German law, he is not entitled to exclude from gross income one-half of his earnings as belonging to his nonresident alien wife.
1Opinion of the Court
CHANNING KING HALL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hall v. Commissioner
Docket No. 6379-75.
United States Tax Court
T.C. Memo 1978-360; 1978 Tax Ct. Memo LEXIS 158; 37 T.C.M. (CCH) 1500; T.C.M. (RIA) 78360;
September 12, 1978, Filed
P, a U.S. citizen, was a civilian employee of the U.S. Army from 1953 through Dec. 31, 1971. P's wife was a citizen of France. The couple resided in Morocco from 1953 to 1959, in France from 1959 to 1967, and in Germany from 1967 through 1971. Held, P failed to establish that his domicile for 1970 and 1971 was other than Germany, where he…
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