McComish v. Commissioner
United States Tax Court
T, a United States citizen, was employed by the government of the Trust Territory of the Pacific Islands where he lived during such employment. Held, the government of the Trust Territory of the Pacific Islands is an "agency" of the United States as intended by sec. 911(a)(2), I.R.C. 1954, and the amounts which it paid to T are therefore not excludable from T's gross income under that Code section.
1Opinion of the Court
OPINION
Raum, Judge:
The Commissioner determined a deficiency of $2,810.45 in petitioners’ Federal income tax for the calendar year 1968. The single issue to be resolved is whether amounts received by petitioner1 from the government of the Trust Territory of the Pacific Islands for services rendered there by petitioner are exempt from Federal income taxation by reason of section 911(a)(2), I.R.C. 1954. The facts have been stipulated by the parties.
At the time of filing their petition herein, petitioners John D. McComish and Genevieve A. McComish, husband and wife, were legal residents of…
2Cases cited21 opinions
- Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
- Standard Oil Co. of Cal. v. JohnsonSupreme Court of the United States · 1942
- Helvering v. Morgan's, Inc.Supreme Court of the United States · 1934
- Porter v. United StatesUnited States Court of Claims · 1974
- The People Of Saipan v. United States Department Of InteriorCourt of Appeals for the Ninth Circuit · 1974
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3Cited by13 opinions
- John D. McComish and Genevieve A. McComish v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1978
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- Julia R. & Estelle L. Foundation, Inc. v. CommissionerUnited States Tax Court · 1978
- Soboleski v. CommissionerUnited States Tax Court · 1987
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