Legal Opinion

Dawson v. Commissioner

United States Tax Court

Decided November 20, 1972No. Docket No. 474-69Published

T, an American citizen employed by an American corporation and residing in the United States, was notified that he would be transferred to Australia, and was placed on the payroll of his employer's Australian subsidiary on Dec. 30, 1965. In anticipation of the transfer, he and his family left the United States (Hawaii) on Dec. 27, 1965. However, as a result of several personal stopovers, he did not arrive in Australia until Jan. 3, 1966. He reported for work on that day.

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T, an American citizen employed by an American corporation and residing in the United States, was notified that he would be transferred to Australia, and was placed on the payroll of his employer's Australian subsidiary on Dec. 30, 1965. In anticipation of the transfer, he and his family left the United States (Hawaii) on Dec. 27, 1965. However, as a result of several personal stopovers, he did not arrive in Australia until Jan. 3, 1966. He reported for work on that day. Dec. 31, 1965, and Jan. 1 and 2, 1966, were holidays in Australia. He and his family intended to make their home in…

1Opinion of the Court

Donald F. and Eleanore A. Dawson, Petitioners v. Commissioner of Internal Revenue, Respondent

Dawson v. Commissioner

Docket No. 474-69

United States Tax Court

59 T.C. 264; 1972 U.S. Tax Ct. LEXIS 23;

November 20, 1972, Filed

Decision will be entered for the respondent.

T, an American citizen employed by an American corporation and residing in the United States, was notified that he would be transferred to Australia, and was placed on the payroll of his employer's Australian subsidiary on Dec. 30, 1965. In anticipation of the transfer, he and his family left the United States (Hawaii) on Dec. 27,…

2Cases cited12 opinions

  1. National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
  2. Howard J. Sochurek v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1962
  3. Downs v. COMMISSIONER OF INTERNAL REVENUE.Court of Appeals for the Ninth Circuit · 1948
  4. Swenson v. ThomasCourt of Appeals for the Fifth Circuit · 1947
  5. Nelson v. CommissionerUnited States Tax Court · 1958

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