Mooneyhan v. Commissioner
United States Tax Court
Petitioner was in Iran from Sept. 29, 1957, to Sept. 29, 1959, and from June 19, 1960, to June 24, 1962, working as an employee of the Bureau of Public Roads of the Department of Commerce pursuant to an agreement between that Bureau and the Iranian Government that his compensation would be paid or reimbursed from a Dollar Working Fund deposited by Iran with the U.S. Treasury.
Read the full summary
Petitioner was in Iran from Sept. 29, 1957, to Sept. 29, 1959, and from June 19, 1960, to June 24, 1962, working as an employee of the Bureau of Public Roads of the Department of Commerce pursuant to an agreement between that Bureau and the Iranian Government that his compensation would be paid or reimbursed from a Dollar Working Fund deposited by Iran with the U.S. Treasury. Held, petitioner was not paid by the United States or an agency thereof while working in Iran and since he also otherwise meets the requirements of sec. 911(a)(2), I.R.C. 1954, is entitled to exclude from his gross…
1Opinion of the Court
Scott, Judge:
Respondent determined deficiencies in petitioner’s income tax for the calendar years 1959, 1960, 1961, and 1962 in the amounts of $1,952.15, $863.26, $2,634.22, and $2,063.32, respectively.
The issues for decision are:(1) Whether petitioner is entitled to exclude from his gross income in each of the years here involved, under the provisions of section 911(a) (2) of the Internal Revenue Code of 1954,1 the salaries he received while working in Iran as an employee of the Bureau of Public Roads, Department of Commerce, assigned to the Iran Division.(2) If not otherwise entitled to…
2Cases cited7 opinions
- Krichbaum v. United StatesDistrict Court, E.D. Tennessee · 1956
- Teskey v. CommissionerUnited States Tax Court · 1958
- Commissioner of Internal Revenue v. Eldon E. Wolfe and Sara A. WolfeCourt of Appeals for the D.C. Circuit · 1966
- Sverdrup v. CommissionerUnited States Tax Court · 1950
- George Y. Erlandson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
2 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Commissioner of Internal Revenue v. Louis H. MooneyhanCourt of Appeals for the Sixth Circuit · 1968
- McComish v. CommissionerUnited States Tax Court · 1975
- Smith v. CommissionerUnited States Tax Court · 1981
- United States v. John C. Johnson and Lillian F. JohnsonCourt of Appeals for the Fifth Circuit · 1967
- Soboleski v. CommissionerUnited States Tax Court · 1987
9 more not listed; retrieve them via the Exa API.