Huff v. Commissioner
United States Tax Court
Claiming to be a bona fide resident of the U.S.Virgin Islands at the close of 2002, 2003, and 2004, and claiming he was qualified for the gross income tax exclusion provided by I.R.C. sec. 932(c)(4), P, a U.S. citizen, filed territorial income tax returns with the Virgin Islands Bureau of Internal Revenue. He did not file Federal income tax returns for those years.
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Claiming to be a bona fide resident of the U.S.Virgin Islands at the close of 2002, 2003, and 2004, and claiming he was qualified for the gross income tax exclusion provided by I.R.C. sec. 932(c)(4), P, a U.S. citizen, filed territorial income tax returns with the Virgin Islands Bureau of Internal Revenue. He did not file Federal income tax returns for those years. R determined that P was not a bona fide resident of the Virgin Islands and was not qualified for the gross income tax exclusion as claimed. Therefore, R issued a notice of deficiency determining income tax deficiencies and…
1Opinion of the Court
OPINION
Jacobs, Judge:
This case is before the Court on petitioner’s motion to dismiss for lack of jurisdiction. The specific question to be decided is whether this Court has jurisdiction to redetermine Federal income tax deficiencies and penalties of a U.S. citizen who claims (1) to be a bona fide resident of the U.S. Virgin Islands at the close of each of the years at issue (i.e., 2002, 2003, and 2004), and (2) to be exempt from U.S. tax filing and payment requirements as a consequence of his satisfying all the requirements of section 932(c)(4).
All section references are to the Internal…
2Cases cited9 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Cook v. TaitSupreme Court of the United States · 1924
- United States v. KaiserSupreme Court of the United States · 1960
- Kluger v. CommissionerUnited States Tax Court · 1984
- Hannan v. CommissionerUnited States Tax Court · 1969
4 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Huff v. CommissionerUnited States Tax Court · 2012
- Appleton v. Comm'rUnited States Tax Court · 2013
- Bartholomew v. District of Columbia Office of Tax & RevenueDistrict of Columbia Court of Appeals · 2013
- Huff v. CommissionerUnited States Tax Court · 2010
- Sanders v. Comm'rUnited States Tax Court · 2015
8 more not listed; retrieve them via the Exa API.