Goldring v. Commissioner
United States Board of Tax Appeals
1. RESIDENCE. - The Commissioner determined that petitioner was a resident alien during 1933. On the evidence that petitioner bought property in the United States in 1930, that he was in the United States some part of the time in subsequent years and lived in the United States continuously from January 1 to May 24, 1933, and on the latter date definitely determined to take up permanent residence in Canada, held, that he was a resident of the United States in the period…
Read the full summary
1. RESIDENCE. - The Commissioner determined that petitioner was a resident alien during 1933. On the evidence that petitioner bought property in the United States in 1930, that he was in the United States some part of the time in subsequent years and lived in the United States continuously from January 1 to May 24, 1933, and on the latter date definitely determined to take up permanent residence in Canada, held, that he was a resident of the United States in the period January 1 to may 24, 1933, and not during the remainder of the year. 2. TRUST INCOME PAID TO DIVORCED WIFE. - In 1930…
1Opinion of the Court
*782OPINION.
Arundell:
This proceeding raises two questions. First, whether or not the petitioner was a resident of the United States after May 24, 1933. Second, whether he is taxable on the income from the trust created in 1930 for the benefit of his wife and children. In determining the deficiency, herein the respondent regarded the petitioner as a resident of the United States during the entire year 1933, and treated as taxable to him the $9,600 payable to petitioner’s divorced wife for her use and also the $2,400 payable to her for the support of the two children.
*783In the amended petition filed…
2Cases cited4 opinions
- Douglas v. WillcutsSupreme Court of the United States · 1935
- Helvering v. StokesSupreme Court of the United States · 1935
- Helvering v. CoxeySupreme Court of the United States · 1936
- Guy T. Helvering, Commissioner of Internal Revenue v. Edmund O. Schweitzer.Supreme Court of the United States · 1935
3Cited by11 opinions
- Friedman v. CommissionerUnited States Tax Court · 1961
- Estate of Petschek v. CommissionerUnited States Tax Court · 1983
- Simenon v. CommissionerUnited States Tax Court · 1965
- Joseph Van Der Elst v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1955
- Craig v. CommissionerUnited States Tax Court · 1980
6 more not listed; retrieve them via the Exa API.