Jellinek v. Commissioner
United States Tax Court
Rudolf Jellinek, a former Czech citizen but stateless during the years involved, was living in Frankfort, Germany, working for Paramount, prior to 1951. He came to the United States on October 19, 1951, at the invitation of his employer, bringing only enough clothes for traveling and leaving his furniture and other belongings in his home in Frankfort. Shortly after arriving in New York Rudolf filed a declaration of intention to become an American citizen.
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Rudolf Jellinek, a former Czech citizen but stateless during the years involved, was living in Frankfort, Germany, working for Paramount, prior to 1951. He came to the United States on October 19, 1951, at the invitation of his employer, bringing only enough clothes for traveling and leaving his furniture and other belongings in his home in Frankfort. Shortly after arriving in New York Rudolf filed a declaration of intention to become an American citizen. Upon finding that he could not obtain satisfactory employment in this country, Rudolf returned to Frankfort on December 11, 1951, after…
1Opinion of the Court
Drennen, Judge:
Respondent determined deficiencies in income tax against petitioners for the taxable years 1952,1953,1954, and 1955 in the respective amounts of $4,458.69, $4,155, $4,225.17, and $3,550.12.
The sole issue is whether petitioner Rudolf Jellinek (hereinafter referred to as Rudolf) was a nonresident alien during the period 1952 through 1955.
The evidence consisted of a stipulation of facts with exhibits attached and the depositions of the two petitioners taken in Vienna, Austria, on written interrogatories and cross-interrogatories.
FINDINGS OF'FACT.
The stipulated facts are found as…
2Cases cited22 opinions
- Glenn Weible and Patricia Weible v. United StatesCourt of Appeals for the Ninth Circuit · 1957
- Johnson v. CommissionerUnited States Tax Court · 1946
- Downs v. CommissionerUnited States Tax Court · 1946
- Robert A. Henningsen, and Cross and R.A. And Margaret Henningsen v. Commissioner of Internal Revenue, AndCourt of Appeals for the Fourth Circuit · 1957
- Downs v. COMMISSIONER OF INTERNAL REVENUE.Court of Appeals for the Ninth Circuit · 1948
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3Cited by27 opinions
- Adams v. CommissionerUnited States Tax Court · 1966
- Dillin v. CommissionerUnited States Tax Court · 1971
- Brittingham v. CommissionerUnited States Tax Court · 1976
- Ferrer v. CommissionerUnited States Tax Court · 1968
- Marsh v. CommissionerUnited States Tax Court · 1977
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