Bogner v. State Dept. of Revenue and Tax.

BISTLINE, Justice.

HISTORY

The plaintiff-respondent, Rosmarie Bogner, is a West German citizen and has been a resident of Idaho since 1981. Her principal source of income is derived from a family business in West Germany. As a German citizen residing in Idaho, plaintiff is taxed on her German income by three governmental entities: West Germany, the United States, and Idaho.

In 1982, plaintiff filed a 1981 income tax return with the Internal Revenue Service. On this return, she claimed a credit for taxes paid to West Germany pursuant to Internal Revenue Code § 901. At about the same time,…