Appleton v. Comm'r
United States Tax Court
P, a U.S. citizen, was a permanent resident of the U.S.Virgin Islands during 2002, 2003, and 2004. P timely filed Form 1040, U.S.
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P, a U.S. citizen, was a permanent resident of the U.S.Virgin Islands during 2002, 2003, and 2004. P timely filed Form 1040, U.S. Individual Income Tax Return, for each year as a territorial tax return with the U.S.Virgin Islands Bureau of Internal Revenue (VIBIR) pursuant to I.R.C. sec. 932(c)(2). Claiming he qualified for the gross income tax exclusion provided by I.R.C. sec. 932(c)(4), P did not file a Federal tax return for 2002, 2003, or 2004 or pay income tax to the Internal Revenue Service. More than three years after P filed his tax returns, R mailed P a notice of deficiency…
1Opinion of the Court
ARTHUR I. APPLETON, JR., Petitioner, AND THE GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, Intervenor v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Appleton v. Comm'r
Docket No. 7717-10.
United States Tax Court
140 T.C. 273; 2013 U.S. Tax Ct. LEXIS 15; 140 T.C. No. 14;
May 22, 2013, Filed
Appleton v. Comm'r, 430 Fed. Appx. 135, 2011 U.S. App. LEXIS 11824 (3d Cir., 2011)
An appropriate order and decision will be entered.
P, a U.S. citizen, was a permanent resident of the U.S.Virgin Islands during 2002, 2003, and 2004. P timely filed Form 1040, U.S. Individual Income Tax Return, for each year as a…
2Cases cited35 opinions
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- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- Dahlstrom v. CommissionerUnited States Tax Court · 1985
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