Laughlin v. Commissioner
United States Tax Court
Citizen Resident of Foreign Country -- Exclusion of Income from Sources Without the United States -- Returned to United States on Termination of Foreign Assignment and Termination of Employment -- Sec. 116 (a) (1). -- A citizen residing in foreign countries for several years as an employee of U. N. R. R. A. had her foreign assignment terminated in December 1947 and obtained an assignment to the United States to which she desired to return for necessary medical treatment.
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Citizen Resident of Foreign Country -- Exclusion of Income from Sources Without the United States -- Returned to United States on Termination of Foreign Assignment and Termination of Employment -- Sec. 116 (a) (1). -- A citizen residing in foreign countries for several years as an employee of U. N. R. R. A. had her foreign assignment terminated in December 1947 and obtained an assignment to the United States to which she desired to return for necessary medical treatment. She returned, had the treatment, and her employment by U. N. R. R. A. was permanently terminated on January 31, 1948. She…
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner determined a deficiency in income tax of $61.99 for 1948. The parties have filed a stipulation in which they have settled their differences for 1949, for which year the Commissioner also determined a deficiency, and have set forth the facts covering the only issue left for decision. That is whether earned income from sources without the United States received by the petitioner during the calendar year 1948 is to be excluded from her taxable income under section 116 (a) (1) because she was “a bona fide resident of a foreign country or countries during…
2Cases cited5 opinions
- Baehre v. CommissionerUnited States Tax Court · 1950
- Seeley v. Commissioner of Internal Revenue. Seeley v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1951
- Seeley v. CommissionerUnited States Tax Court · 1950
- Wood v. United StatesUnited States Court of Claims · 1952
- Flanagan v. CommissionerUnited States Tax Court · 1952
3Cited by5 opinions
- Blaess v. CommissionerUnited States Tax Court · 1957
- Carpenter v. United StatesDistrict Court, N.D. Texas · 1972
- Blaess v. CommissionerUnited States Tax Court · 1957
- Laughlin v. CommissionerUnited States Tax Court · 1956
- Young v. CommissionerUnited States Tax Court · 1974