Legal Opinion

Marsh v. Commissioner

United States Tax Court

Decided April 25, 1977No. Docket No. 2046-73Published

Held: Petitioner, an alien who established residence in the United States in 1962, did not abandon such resident status when she departed the country in 1966 and remained abroad for 4 years. Accordingly, one-half of her husband's income from sources without the United States, attributable to petitioner under the community property laws of Louisiana (her husband's domicile), is taxable to petitioner.

1Opinion of the Court

Kazuko S. Marsh, Petitioner v. Commissioner of Internal Revenue, Respondent

Marsh v. Commissioner

Docket No. 2046-73

United States Tax Court

68 T.C. 68; 1977 U.S. Tax Ct. LEXIS 119;

April 25, 1977, Filed

Decision will be entered for the respondent.

Held: Petitioner, an alien who established residence in the United States in 1962, did not abandon such resident status when she departed the country in 1966 and remained abroad for 4 years. Accordingly, one-half of her husband's income from sources without the United States, attributable to petitioner under the community property laws of Louisiana (her…

2Cases cited8 opinions

  1. Adams v. CommissionerUnited States Tax Court · 1966
  2. Dillin v. CommissionerUnited States Tax Court · 1971
  3. Brittingham v. CommissionerUnited States Tax Court · 1976
  4. Friedman v. CommissionerUnited States Tax Court · 1961
  5. Baer v. CommissionerUnited States Tax Court · 1946

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