Brewster v. Commissioner
United States Tax Court
Held, the Commissioner properly determined that petitioner, who had earned income from sources without the United States, could not claim a deduction from gross income, of a portion of her expenses, since a portion of such expenses was properly allocable to or chargeable against amounts excluded from gross income. Sec. 911(a) and (b), I.R.C. 1954.
1Opinion of the Court
Anne Moen Bullitt Brewster, Petitioner v. Commissioner of Internal Revenue, Respondent
Brewster v. Commissioner
Docket No. 3672-67
United States Tax Court
55 T.C. 251; 1970 U.S. Tax Ct. LEXIS 40;
October 29, 1970, Filed
Decision will be entered under Rule 50.
Held, the Commissioner properly determined that petitioner, who had earned income from sources without the United States, could not claim a deduction from gross income, of a portion of her expenses, since a portion of such expenses was properly allocable to or chargeable against amounts excluded from gross income. Sec. 911(a) and (b), I.R.C.…
Also in this document: Dissent.
2Cases cited3 opinions
- Miller v. CommissionerUnited States Tax Court · 1969
- Brewster v. CommissionerUnited States Tax Court · 1970
- Hempel v. CommissionerUnited States Tax Court · 1947