Riley v. Commissioner
United States Tax Court
Petitioner, a U.S. citizen, went to Canada in 1973 to teach at a university there. He intended to remain in Canada indefinitely but returned to the United States within 2 years of his entrance into Canada because his teaching contract was terminated and he was unable to find other employment.
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Petitioner, a U.S. citizen, went to Canada in 1973 to teach at a university there. He intended to remain in Canada indefinitely but returned to the United States within 2 years of his entrance into Canada because his teaching contract was terminated and he was unable to find other employment. Upon leaving Canada, petitioner applied for exemption from Canadian income taxes as a visiting teacher under art. VIII A of the United States-Canada Income Tax Convention and obtained refunds of Canadian income taxes for the years 1973 and 1974. Held, in claiming exemption from Canadian income tax under…
1Opinion of the Court
Paul V. Riley, Jr., Petitioner v. Commissioner of Internal Revenue, Respondent
Riley v. Commissioner
Docket No. 10896-76
United States Tax Court
74 T.C. 414; 1980 U.S. Tax Ct. LEXIS 129;
May 27, 1980, Filed
Decision will be entered for the petitioner.
Petitioner, a U.S. citizen, went to Canada in 1973 to teach at a university there. He intended to remain in Canada indefinitely but returned to the United States within 2 years of his entrance into Canada because his teaching contract was terminated and he was unable to find other employment. Upon leaving Canada, petitioner applied for exemption from…
2Cases cited10 opinions
- Howard J. Sochurek v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1962
- Adams v. CommissionerUnited States Tax Court · 1966
- Dawson v. CommissionerUnited States Tax Court · 1972
- Sochurek v. CommissionerUnited States Tax Court · 1961
- Simenon v. CommissionerUnited States Tax Court · 1965
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