Cini v. Commissioner
United States Tax Court
Petitioner, a U.S. citizen residing in France, was employed by J-M Europe Corp., a Delaware corporation subsidiary of Johns-Manville Corp., as an executive overseeing the operations of various subsidiaries of Johns-Manville Corp. which were doing business in Europe. Petitioner worked part of the time within the United States and part of the time without the United States.
Read the full summary
Petitioner, a U.S. citizen residing in France, was employed by J-M Europe Corp., a Delaware corporation subsidiary of Johns-Manville Corp., as an executive overseeing the operations of various subsidiaries of Johns-Manville Corp. which were doing business in Europe. Petitioner worked part of the time within the United States and part of the time without the United States. Petitioner received from his employer as compensation for his services a basic salary and bonuses based on the earnings of the foreign subsidiaries of Johns-Manville Corp. and on the export earnings of Johns-Manville Corp.…
1Opinion of the Court
OPINION
Drennen, Judge:
In these consolidated cases respondent determined deficiencies in petitioners’ income taxes for the taxable years indicated as follows:
Docket
No. Petitioner Year Deficiency
4962-75 Antoine L. Cini. 1970 $2,262.87
1972 2,504.73
5115-75 Gertrud Cini. 1970 2,689.52
1972 1,456.40
Due to concessions by the parties the only issue remaining for decision is whether respondent has properly determined the portion of the income of Antoine L. Cini which is attributable to sources within the United States as opposed to foreign sources; specifically, whether bonuses received by Antoine L.…
2Cited by5 opinions
- Stemkowski v. CommissionerUnited States Tax Court · 1981
- Filler v. CommissionerUnited States Tax Court · 1980
- Cini v. CommissionerUnited States Tax Court · 1977
- Filler v. CommissionerUnited States Tax Court · 1980
- Stemkowski v. CommissionerUnited States Tax Court · 1981