Eshel v. Comm'r
United States Tax Court
In 1987, the United States and France entered into a Totalization Agreement to coordinate benefits under their respective social security systems. Section 317(b)(4) of the Social Security Amendments of 1977 (SSA), Pub.
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In 1987, the United States and France entered into a Totalization Agreement to coordinate benefits under their respective social security systems. Section 317(b)(4) of the Social Security Amendments of 1977 (SSA), Pub. L. No. 95-216, 91 Stat. at 1540, provides that, notwithstanding any other provision of law, taxes paid by an individual to a foreign country "in accordance with the terms of" a totalization agreement shall not be creditable or deductible for Federal income tax purposes. In 2008 and 2009 Ps paid two taxes to the French Government --la contribution sociale généralisée (CSG) and…
1Opinion of the Court
ORY ESHEL AND LINDA CORYELL ESHEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Eshel v. Comm'r
Docket No. 8055-12
United States Tax Court
142 T.C. 197; 2014 U.S. Tax Ct. LEXIS 11; 142 T.C. No. 11;
April 2, 2014, Filed
An appropriate order will be issued, and decision will be entered under Rule 155.
In 1987, the United States and France entered into a Totalization Agreement to coordinate benefits under their respective social security systems. Section 317(b)(4) of the Social Security Amendments of 1977 (SSA), Pub. L. No. 95-216, 91 Stat. at 1540, provides that, notwithstanding any…
2Cases cited31 opinions
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- Hughes Aircraft Co. v. JacobsonSupreme Court of the United States · 1999
- Volkswagenwerk Aktiengesellschaft v. SchlunkSupreme Court of the United States · 1988
- Estate of Cowart v. Nicklos Drilling Co.Supreme Court of the United States · 1992
- Medellin v. TexasSupreme Court of the United States · 2008
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