Legal Opinion

Connelly v. Commissioner

United States Tax Court

Decided April 21, 1947No. Docket No. 10372Published

1. In the taxable years 1943 and 1944, petitioner William I. Connelly, a Government employee holding a classified civil service position, was enrolled as a temporary member of the Coast Guard Reserve, with a rank or rating of Lieutenant Commander, and later, Commander. The certificate under which he was enrolled stated he was to serve without pay and allowances other than the compensation of his civilian position.

Read the full summary

1. In the taxable years 1943 and 1944, petitioner William I. Connelly, a Government employee holding a classified civil service position, was enrolled as a temporary member of the Coast Guard Reserve, with a rank or rating of Lieutenant Commander, and later, Commander. The certificate under which he was enrolled stated he was to serve without pay and allowances other than the compensation of his civilian position. Held: (a) Petitioner was not a commissioned officer of the Coast Guard Reserve entitling him to a tax exclusion of $ 1,500 in the respective taxable years, within the purview of…

1Opinion of the Court

William I. Connelly and Bertha Connelly, Petitioners, v. Commissioner of Internal Revenue, Respondent

Connelly v. Commissioner

Docket No. 10372

United States Tax Court

8 T.C. 848; 1947 U.S. Tax Ct. LEXIS 226;

April 21, 1947, Promulgated

Decision will be entered for the respondent.

1. In the taxable years 1943 and 1944, petitioner William I. Connelly, a Government employee holding a classified civil service position, was enrolled as a temporary member of the Coast Guard Reserve, with a rank or rating of Lieutenant Commander, and later, Commander. The certificate under which he was enrolled stated he…

2Cases cited2 opinions

  1. Bank of Commerce v. Tennessee Ex Rel. MemphisSupreme Court of the United States · 1896
  2. Connelly v. CommissionerUnited States Tax Court · 1947

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API