Henningsen v. Commissioner
United States Tax Court
1. Held, petitioner, a citizen of the United States, who claims to have been a bona fide resident of China, became a resident of the United States sometime between November 1941 and February 1946, during all of which period he was in the United States. 2. Held, petitioner was not a bona fide resident of a foreign country or countries for the entire year 1946 or 1947, or for a period of at least 2 years before the date in 1947 on which he reestablished his residence in the…
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1. Held, petitioner, a citizen of the United States, who claims to have been a bona fide resident of China, became a resident of the United States sometime between November 1941 and February 1946, during all of which period he was in the United States. 2. Held, petitioner was not a bona fide resident of a foreign country or countries for the entire year 1946 or 1947, or for a period of at least 2 years before the date in 1947 on which he reestablished his residence in the United States. 3. Respondent's imposition of an addition to tax for failure to file a return in 1946, sustained. 4. Held,…
1Opinion of the Court
Robert A. Henningsen, Petitioner, v. Commissioner of Internal Revenue, Respondent. R. A. and Margaret Henningsen, Petitioners, v. Commissioner of Internal Revenue, Respondent
Henningsen v. Commissioner
Docket Nos. 52544, 52545
United States Tax Court
26 T.C. 528; 1956 U.S. Tax Ct. LEXIS 161;
June 13, 1956, Filed
Decisions will be entered under Rule 50.
1. Held, petitioner, a citizen of the United States, who claims to have been a bona fide resident of China, became a resident of the United States sometime between November 1941 and February 1946, during all of which period he was in the United States.
2Cases cited15 opinions
- Avery v. CommissionerSupreme Court of the United States · 1934
- Johnson v. CommissionerUnited States Tax Court · 1946
- Marsman v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
- Commissioner of Internal Revenue v. NubarCourt of Appeals for the Fourth Circuit · 1950
- Marsman v. CommissionerUnited States Tax Court · 1952
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