Darrell F. Brown v. Commissioner of Internal Revenue

Darrell Brown appeals from the memorandum decision of the United States Tax Court 1 assessing a tax deficiency against him for the years 1975 and 1976. 44 T.C.M. (CCH) 481 (1982).

During the years in question Brown resided in the Panama Canal Zone and was employed as a magistrate by the Canal Zone Government. Brown asserts that under section 119 of the Internal Revenue Code he is entitled to exclude from his gross income the value of certain deductions from his wages. 26 U.S.C. § 119 (1976 & Supp. V 1981). 2 As magistrate, Brown was required to live in the Canal Zone; however, no private…