Hagerty v. Commissioner
United States Tax Court
During 1963 and the major portion of 1964 petitioners traveled throughout Europe selling the products of the American corporation. In October of 1964 they returned to Europe, settling in France, to assist their customers in merchandising the products sold in the earlier years, to create and test new marketing and advertising ideas for the American corporation and to form a European sales office which would take over the selling activities of the American corporation.
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During 1963 and the major portion of 1964 petitioners traveled throughout Europe selling the products of the American corporation. In October of 1964 they returned to Europe, settling in France, to assist their customers in merchandising the products sold in the earlier years, to create and test new marketing and advertising ideas for the American corporation and to form a European sales office which would take over the selling activities of the American corporation. Petitioners returned to the United States in June of 1966. Held: Petitioners were bona fide residents of a foreign country for…
1Opinion of the Court
CAROL PATTON HAGERTY (Formerly Mrs. Carol Patton), 1 Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hagerty v. Commissioner
Docket Nos. 4034-70, 4792-70, 5497-70
United States Tax Court
T.C. Memo 1973-162; 1973 Tax Ct. Memo LEXIS 125; 32 T.C.M. (CCH) 788; T.C.M. (RIA) 73162;
July 24, 1973, Filed
During 1963 and the major portion of 1964 petitioners traveled throughout Europe selling the products of the American corporation. In October of 1964 they returned to Europe, settling in France, to assist their customers in merchandising the products sold in the earlier years, to create and test…
2Cases cited8 opinions
- Howard J. Sochurek v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1962
- Nelson v. CommissionerUnited States Tax Court · 1958
- Sochurek v. CommissionerUnited States Tax Court · 1961
- Miller v. CommissionerUnited States Tax Court · 1969
- White v. CommissionerUnited States Tax Court · 1954
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