de Vegvar v. Commissioner
United States Tax Court
Petitioner was a nonresident alien with substantial assets in a custody account in the United States. A power of attorney executed by petitioner made two attorneys with offices in New York his attorneys in fact. In the taxable period at issue the attorneys purchased and sold securities, made one sale of commodity futures, and were the officers and directors of two Florida corporations which were wholly owned by petitioner.
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Petitioner was a nonresident alien with substantial assets in a custody account in the United States. A power of attorney executed by petitioner made two attorneys with offices in New York his attorneys in fact. In the taxable period at issue the attorneys purchased and sold securities, made one sale of commodity futures, and were the officers and directors of two Florida corporations which were wholly owned by petitioner. Held, on the facts of this case petitioner was not engaged in trade or business within the meaning of section 211 (b), I. R. C. 1939.
1Opinion of the Court
Edward A. Neuman de Vegvar, Petitioner, v. Commissioner of Internal Revenue, Respondent
de Vegvar v. Commissioner
Docket No. 58742
United States Tax Court
28 T.C. 1055; 1957 U.S. Tax Ct. LEXIS 109;
August 27, 1957, Filed
Decision will be entered under Rule 50.
Petitioner was a nonresident alien with substantial assets in a custody account in the United States. A power of attorney executed by petitioner made two attorneys with offices in New York his attorneys in fact. In the taxable period at issue the attorneys purchased and sold securities, made one sale of commodity futures, and were the officers…
2Cases cited4 opinions
- Adda v. CommissionerUnited States Tax Court · 1948
- Adda v. COMMISSIONER OF INTERNAL REVENUECourt of Appeals for the Fourth Circuit · 1948
- Joseph Van Der Elst v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1955
- de Vegvar v. CommissionerUnited States Tax Court · 1957