Parsons v. Commissioner
United States Tax Court
Held, that a wife who is a member of a Philippine conjugal partnership and who is an American citizen domiciled in the Philippines has such interests under Philippine law in the property of such partnership as to make one-half of the income becoming the capital of the partnership taxable to her under the Internal Revenue Code of the United States.
1Opinion of the Court
Katrushka J. Parsons, Petitioner, v. Commissioner of Internal Revenue, Respondent
Parsons v. Commissioner
Docket Nos. 2689-62, 2376-63
United States Tax Court
43 T.C. 331; 1964 U.S. Tax Ct. LEXIS 6;
December 24, 1964, Filed December 24, 1964, Filed
Held, that a wife who is a member of a Philippine conjugal partnership and who is an American citizen domiciled in the Philippines has such interests under Philippine law in the property of such partnership as to make one-half of the income becoming the capital of the partnership taxable to her under the Internal Revenue Code of the United States.
John M.…
2Cases cited17 opinions
- Poe v. SeabornSupreme Court of the United States · 1930
- Helvering v. StuartSupreme Court of the United States · 1942
- Burnet v. WellsSupreme Court of the United States · 1933
- United States v. RobbinsSupreme Court of the United States · 1926
- Marsman v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
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