Wolfe v. Commissioner
United States Tax Court
Petitioner, an employee of the Bureau of Public Roads of the U.S. Department of Commerce, was assigned to do work in Iran pursuant to an agreement by which his salary was to be paid from funds to be deposited by Iran with the Bureau.
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Petitioner, an employee of the Bureau of Public Roads of the U.S. Department of Commerce, was assigned to do work in Iran pursuant to an agreement by which his salary was to be paid from funds to be deposited by Iran with the Bureau. Accordingly, Iran borrowed (and later repaid) the necessary funds from the Export-Import Bank, deposited them in a trust account with the Bureau, and petitioner's salary was paid from this fund by checks drawn by the Treasurer of the United States. Held, the amounts of such salary were not "amounts paid by the United States or any agency thereof" within the…
1Opinion of the Court
Respondent determined deficiencies in petitioners’ income tax for the years 1959 and 1960 in the respective amounts of $2,399.97 and $1,579.95. In his statutory notice of deficiency respondent determined that the petitioners had excluded from their gross income during the years in question amounts which were properly subject to tax because they did not represent exempt income under section 911 of the Internal Revenue Code of 1954. In the petition it is alleged that the source of petitioners’ income for the years before us was from a fund owned by the Imperial Government of Iran, and that…
2Cases cited4 opinions
- Krichbaum v. United StatesDistrict Court, E.D. Tennessee · 1956
- Teskey v. CommissionerUnited States Tax Court · 1958
- Sverdrup v. CommissionerUnited States Tax Court · 1950
- George Y. Erlandson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
3Cited by18 opinions
- Commissioner of Internal Revenue v. Louis H. MooneyhanCourt of Appeals for the Sixth Circuit · 1968
- Commissioner of Internal Revenue v. Eldon E. Wolfe and Sara A. WolfeCourt of Appeals for the D.C. Circuit · 1966
- Mooneyhan v. CommissionerUnited States Tax Court · 1967
- McComish v. CommissionerUnited States Tax Court · 1975
- Smith v. CommissionerUnited States Tax Court · 1981
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