Abrahamsen v. Comm'r
United States Tax Court
I.R.C. sec. 893 excludes from gross income and exempts from taxation income received by an employee of a foreign government or international organization if certain conditions are met. The I.R.C. sec. 893 exemption can be waived, and it must be waived by a person who wishes to become a permanent resident of the United States. The exemption does not apply to income received by a permanent resident after filing the waiver. Sec. 1.893-1(b)(5), Income Tax Regs.
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I.R.C. sec. 893 excludes from gross income and exempts from taxation income received by an employee of a foreign government or international organization if certain conditions are met. The I.R.C. sec. 893 exemption can be waived, and it must be waived by a person who wishes to become a permanent resident of the United States. The exemption does not apply to income received by a permanent resident after filing the waiver. Sec. 1.893-1(b)(5), Income Tax Regs. P-W entered the United States in 1983 to work for Finland's Permanent Mission to the United Nations (Mission) in New York. She left the…
1Opinion of the Court
CLIFFORD A. ABRAHAMSEN AND SOLE K. ABRAHAMSEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Abrahamsen v. Comm'r
Docket No. 20466-11.
United States Tax Court
142 T.C. 405; 2014 U.S. Tax Ct. LEXIS 24; 142 T.C. No. 22;
June 9, 2014, Filed
An appropriate order will be issued.
I.R.C. sec. 893 excludes from gross income and exempts from taxation income received by an employee of a foreign government or international organization if certain conditions are met. The I.R.C. sec. 893 exemption can be waived, and it must be waived by a person who wishes to become a permanent resident of the…
2Cases cited12 opinions
- Dahlstrom v. CommissionerUnited States Tax Court · 1985
- FPL Group, Inc. v. CommissionerUnited States Tax Court · 2001
- Elec. Arts, Inc. v. Comm'rUnited States Tax Court · 2002
- City of New York v. Permanent Mission of India to the United NationsCourt of Appeals for the Second Circuit · 2010
- United States v. CoplonDistrict Court, S.D. New York · 1949
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