Foley v. Commissioner
United States Tax Court
Petitioner, a U.S. citizen, resided and worked in West Berlin, Germany. He received incentive payments pursuant to art. 28 of the Berlin Promotion Law. Held, petitioner properly computed his foreign tax credit, for U.S. income tax purposes, without taking such payments into account. Held, further, such incentive payments are includable in income under sec. 61, I.R.C. 1954.
1Opinion of the Court
James M. Foley, Jr., Petitioner v. Commissioner of Internal Revenue, Respondent
Foley v. Commissioner
Docket No. 5384-83
United States Tax Court
87 T.C. 605; 1986 U.S. Tax Ct. LEXIS 51; 87 T.C. No. 35;
September 17, 1986, Filed
Decision will be entered under Rule 155.
Petitioner, a U.S. citizen, resided and worked in West Berlin, Germany. He received incentive payments pursuant to art. 28 of the Berlin Promotion Law. Held, petitioner properly computed his foreign tax credit, for U.S. income tax purposes, without taking such payments into account. Held, further, such incentive payments are includable…
2Cases cited5 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Filler v. CommissionerUnited States Tax Court · 1980
- Crerar v. CommissionerUnited States Tax Court · 1956
- Foley v. CommissionerUnited States Tax Court · 1986