Legal Opinion

Soboleski v. Commissioner

United States Tax Court

Decided April 22, 1987No. Docket No. 10267-83Published

During 1980 and 1981, petitioner Joseph N. Soboleski was employed as a civil engineer with the U.S. Army Corps of Engineers. Petitioner was assigned to work in the Kingdom of Saudi Arabia where he supervised the construction of a Saudi Arabian military installation. Held, petitioner's salary was paid by an agency of the United States, and therefore he is not entitled to exclude his salary from taxable income under sec. 911(a), I.R.C. 1954.

1Opinion of the Court

Joseph N. and Margaret J. Soboleski, Petitioners v. Commissioner of Internal Revenue, Respondent

Soboleski v. Commissioner

Docket No. 10267-83

United States Tax Court

88 T.C. 1024; 1987 U.S. Tax Ct. LEXIS 55; 88 T.C. No. 56;

April 22, 1987. April 22, 1987, Filed

Decision will be entered for the respondent.

During 1980 and 1981, petitioner Joseph N. Soboleski was employed as a civil engineer with the U.S. Army Corps of Engineers. Petitioner was assigned to work in the Kingdom of Saudi Arabia where he supervised the construction of a Saudi Arabian military installation. Held, petitioner's salary was…

2Cases cited17 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Krichbaum v. United StatesDistrict Court, E.D. Tennessee · 1956
  3. Commissioner of Internal Revenue v. Louis H. MooneyhanCourt of Appeals for the Sixth Circuit · 1968
  4. John D. McComish and Genevieve A. McComish v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1978
  5. Teskey v. CommissionerUnited States Tax Court · 1958

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