Topsnik v. Comm'r
United States Tax Court
In 2004 P, a German citizen, made an installment sale of his stock in a U.S. corporation, and in 2010, the year in issue, he received equal monthly payments pursuant to a promissory note executed in connection with the sale. He filed a late Form 1040NR, U.S. Nonresident Alien Income Tax Return, for 2010 claiming that the installment sale proceeds were exempt from taxation by virtue of the U.S.-Germany Tax Treaty.
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In 2004 P, a German citizen, made an installment sale of his stock in a U.S. corporation, and in 2010, the year in issue, he received equal monthly payments pursuant to a promissory note executed in connection with the sale. He filed a late Form 1040NR, U.S. Nonresident Alien Income Tax Return, for 2010 claiming that the installment sale proceeds were exempt from taxation by virtue of the U.S.-Germany Tax Treaty. On Nov. 20, 2010, P completed paperwork to formally abandon his lawful permanent resident (LPR) status. R determined that P is liable for an income tax deficiency for 2010…
1Opinion of the Court
GERD TOPSNIK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Topsnik v. Comm'r
Docket No. 2482-14.
United States Tax Court
146 T.C. 1; 2016 U.S. Tax Ct. LEXIS 1; 146 T.C. No. 1;
January 20, 2016, Filed
Topsnik v. United States, 2012 U.S. Dist. LEXIS 189638 (C.D. Cal., 2012)
An appropriate order will be issued.
In 2004 P, a German citizen, made an installment sale of his stock in a U.S. corporation, and in 2010, the year in issue, he received equal monthly payments pursuant to a promissory note executed in connection with the sale. He filed a late Form 1040NR, U.S. Nonresident Alien Income…
2Cases cited13 opinions
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Bond v. CommissionerUnited States Tax Court · 1993
- FPL Group, Inc. v. CommissionerUnited States Tax Court · 2001
- Nationalist Movement v. CommissionerCourt of Appeals for the Fifth Circuit · 1994
8 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
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