Legal Opinion

Eren v. Commissioner

Court of Appeals for the Fourth Circuit

Decided June 14, 1999No. 96-1620PublishedCited by 10 opinions

1Opinion of the Court

Affirmed by published opinion. Judge WIDENER wrote the opinion, in which Judge MURNAGHAN and Senior Judge PHILLIPS concurred.

OPINION

WIDENER, Circuit Judge:

Petitioners Ertan and Susan Eren appeal a U.S. Tax Court decision that Ertan Eren’s 1989 income from the U.S. Depart-mént of State, Office of Foreign Buildings Operations (FBO) did not qualify for the foreign earned income exclusion of 26 U.S.C. § 911 (§ 911). The tax court found that Eren’s relationship with his employer was that of an employee rather than an independent contractor, with the consequence that he was not entitled to the §…

2Cases cited10 opinions

  1. Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
  2. Nationwide Mutual Insurance v. DardenSupreme Court of the United States · 1992
  3. James P. Thomas and Mary Lou Thomas v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1986
  4. Charles Franklin GARRETT, Appellant, v. PHILLIPS MILLS, INC., AppelleeCourt of Appeals for the Fourth Circuit · 1983
  5. Michael D. Weber Barbara L. Weber v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Fourth Circuit · 1995

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3Cited by10 opinions

  1. United States v. McBrideDistrict Court, D. Utah · 2012
  2. Qinetiq US Holdings, Inc. & Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 2017
  3. Martin v. Commissioner, IRSCourt of Appeals for the Fourth Circuit · 2002
  4. Alfred S. Co v. Comm'rUnited States Tax Court · 2016
  5. Billesdon v. Wells Fargo Securities, LLCDistrict Court, W.D. North Carolina · 2024

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