Marsh v. Commissioner
United States Tax Court
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
- Adams v. CommissionerUnited States Tax Court · 1966
- Dillin v. CommissionerUnited States Tax Court · 1971
- Brittingham v. CommissionerUnited States Tax Court · 1976
- Friedman v. CommissionerUnited States Tax Court · 1961
- Baer v. CommissionerUnited States Tax Court · 1946
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