Sverdrup v. Commissioner
United States Tax Court
Petitioner, an individual citizen of the United States, was a bona fide nonresident of the United States for more than six months during the taxable year 1942. As a member of an engineering partnership, he received in 1942 the amount of $ 36,279.30 as his distributive share of the net amount derived from four contracts which the partnership entered into with the United States and which were performed by the partnership and another party under a joint venture agreement.
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Petitioner, an individual citizen of the United States, was a bona fide nonresident of the United States for more than six months during the taxable year 1942. As a member of an engineering partnership, he received in 1942 the amount of $ 36,279.30 as his distributive share of the net amount derived from four contracts which the partnership entered into with the United States and which were performed by the partnership and another party under a joint venture agreement. He was also paid in 1942 the amount of $ 5,000 by the joint venture as additional compensation because of the nature of the…
1Opinion of the Court
OPINION.
Johnson, Judge-.
Respondent determined a deficiency in income tax and victory tax for the taxable year 1943 in the amount of $29,466.79. By virtue of the Current Tax Payment Act of 1943 the deficiency is asserted for 1943, although the controversy involves only the year 1942. The sole question is whether petitioner was entitled to exclude from his gross income in 1942 certain amounts totaling $41,279.30 under section 116 (a), Internal Revenue Code, prior to its amendment by section 148 (a) of the Revenue Act of 1942 and by section 107 (b) of the Revenue Act of 1943.
The facts are…
2Cases cited2 opinions
- Neuberger v. CommissionerSupreme Court of the United States · 1940
- Bouldin v. CommissionerUnited States Tax Court · 1947
3Cited by26 opinions
- Krichbaum v. United StatesDistrict Court, E.D. Tennessee · 1956
- Teskey v. CommissionerUnited States Tax Court · 1958
- George Y. Erlandson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
- Pratt v. CommissionerUnited States Tax Court · 1975
- Wolfe v. CommissionerUnited States Tax Court · 1965
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