Hofstetter v. Commissioner
United States Tax Court
During 1988, P, a resident of Switzerland, was a nonresident alien present in the United States engaged in paid research for a law firm. P reported the wages received from his employer during 1988 on a timely filed Form 1040-NR. The wage income was offset by deductions for travel expenses, and meals and entertainment expenses. P did not compute the alternative minimum tax on the return. P reported no income tax due on the return.
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During 1988, P, a resident of Switzerland, was a nonresident alien present in the United States engaged in paid research for a law firm. P reported the wages received from his employer during 1988 on a timely filed Form 1040-NR. The wage income was offset by deductions for travel expenses, and meals and entertainment expenses. P did not compute the alternative minimum tax on the return. P reported no income tax due on the return. P departed the United States in June 1989. As required by law, P met with an agent of the IRS prior to his departure to determine whether he satisfied his…
1Opinion of the Court
OPINION
HALPERN, Judge:
This case was assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge:
This case was submitted fully stipulated pursuant to Rule 122.
In a notice of deficiency dated November 27, 1989, respondent determined a deficiency in petitioner's Federal income tax for taxable year 1988 in the amount of $4,900. Respondent also determined…
2Cases cited14 opinions
- Neely v. CommissionerUnited States Tax Court · 1985
- Bixby v. CommissionerUnited States Tax Court · 1972
- Estate of Emerson v. CommissionerUnited States Tax Court · 1977
- Barclay & Co. v. EdwardsSupreme Court of the United States · 1925
- Pierre Boulez v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1987
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3Cited by54 opinions
- Norfolk Southern Corp. v. CommissionerUnited States Tax Court · 1995
- Greenberg Bros. P'ship 4 v. CommissionerUnited States Tax Court · 1998
- Wilkins v. Comm'rUnited States Tax Court · 2003
- McCorkle v. Comm'rUnited States Tax Court · 2005
- Carlebach v. CommissionerUnited States Tax Court · 2012
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