Brewster v. Commissioner
United States Tax Court
Petitioner, a U.S. citizen residing abroad, operated a farming business as a sole proprietorship in Ireland at a loss. Petitioner's personal services as well as capital were material income-producing factors in the business. Held, under sec. 911(b), petitioner was required to exclude a portion of her gross farm income as "earned income." Brewster v. Commissioner, 473 F.2d 160 (D.C.
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Petitioner, a U.S. citizen residing abroad, operated a farming business as a sole proprietorship in Ireland at a loss. Petitioner's personal services as well as capital were material income-producing factors in the business. Held, under sec. 911(b), petitioner was required to exclude a portion of her gross farm income as "earned income." Brewster v. Commissioner, 473 F.2d 160 (D.C. Cir. 1972), affg. per curiam 55 T.C. 251 (1970); Jack E. Golsen, 54 T.C. 742 (1970), affd. on the substantive issue 445 F.2d 985 (10th Cir. 1971). Held, further, respondent's determination that 30 percent of gross…
1Opinion of the Court
Anne Moen Bullitt Biddle Brewster, Petitioner v. Commissioner of Internal Revenue, Respondent
Brewster v. Commissioner
Docket No. 7063-71
United States Tax Court
67 T.C. 352; 1976 U.S. Tax Ct. LEXIS 17;
November 30, 1976, Filed
Decision will be entered under Rule 155.
Petitioner, a U.S. citizen residing abroad, operated a farming business as a sole proprietorship in Ireland at a loss. Petitioner's personal services as well as capital were material income-producing factors in the business. Held, under sec. 911(b), petitioner was required to exclude a portion of her gross farm income as "earned…
Also in this document: Dissent.
2Cases cited24 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Hellmich v. HellmanSupreme Court of the United States · 1928
- Challenge Mfg. Co. v. CommissionerUnited States Tax Court · 1962
- Stolk v. CommissionerUnited States Tax Court · 1963
- Pepsi--Cola Bottling Company of Salina, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1976
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