Matthew v. Commissioner
United States Tax Court
During the taxable years involved the petitioners were employees of Pan American World Airways engaged in maintaining missile stations on various foreign islands in connection with the United States missile-testing program. Their employment was of indefinite duration, each of them intended to stay on such islands for an indefinite period, and in fact each had stayed on the various islands for a number of years.
Read the full summary
During the taxable years involved the petitioners were employees of Pan American World Airways engaged in maintaining missile stations on various foreign islands in connection with the United States missile-testing program. Their employment was of indefinite duration, each of them intended to stay on such islands for an indefinite period, and in fact each had stayed on the various islands for a number of years. They were quartered in company-furnished barracks at the sites and used the company-furnished dining halls. They were not restricted to the bases, except during working hours, but were…
1Opinion of the Court
Atkins, Judge:
The respondent determined deficiencies in income tax of the petitioners for the taxable years and in the amounts as follows:
[[Image here]]
The question common to each of these consolidated cases is whether the petitioner was a bona fide resident of a foreign country or countries during the years in question with the result that his compensation is excludible from gross income pursuant to section 911(a) (1) of the Internal Revenue Code of 1954. The petitioner Hill also alleges error of the respondent in disallowing certain claimed exemptions.
FINDINGS OF FACT.
Some of the facts have…
2Cases cited18 opinions
- Glenn Weible and Patricia Weible v. United StatesCourt of Appeals for the Ninth Circuit · 1957
- Johnson v. CommissionerUnited States Tax Court · 1946
- Downs v. CommissionerUnited States Tax Court · 1946
- Downs v. COMMISSIONER OF INTERNAL REVENUE.Court of Appeals for the Ninth Circuit · 1948
- Swenson v. ThomasCourt of Appeals for the Fifth Circuit · 1947
13 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Adams v. CommissionerUnited States Tax Court · 1966
- Benfer v. CommissionerUnited States Tax Court · 1965
- Commissioner of Internal Revenue v. Lyon Tyler MatthewCourt of Appeals for the Fifth Circuit · 1964
- Boyd v. CommissionerUnited States Tax Court · 1966
- Brueck v. United StatesDistrict Court, N.D. Indiana · 1963
5 more not listed; retrieve them via the Exa API.