Legal Opinion

Rust v. Commissioner

United States Tax Court

Decided August 15, 1985No. Docket No. 16199-84PublishedCited by 10 opinions

Held, art. XVI of the Agreement in Implementation of Art. IV of the Panama Canal Treaty of 1977, T.I.A.S. Nos. 10030 and 10032, does not exempt U.S. Forces personnel living in the Canal Zone from U.S. income taxation.

1Opinion of the Court

OPINION

Featherston, Judge-.

This case was assigned to Special Trial Judge Hu S. Vandervort pursuant to section 74561 and Rules 180 and 181. The Court agrees with and adopts his opinion which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

Vandervort, Special Trial Judge: This case is before the Court on respondent’s motion for partial summary judgment, filed on May 7, 1985, pursuant to Rule 121.

In the notice of deficiency issued April 4, 1984, respondent determined a deficiency and an addition to tax for the taxable year 1980 as follows:

Sec. 6653(a)

Year Deficiency addition to tax

1980…

2Cases cited20 opinions

  1. Adickes v. S. H. Kress & Co.Supreme Court of the United States · 1970
  2. Sumitomo Shoji America, Inc. v. AvaglianoSupreme Court of the United States · 1982
  3. Jacklin v. CommissionerUnited States Tax Court · 1982
  4. Factor v. LaubenheimerSupreme Court of the United States · 1933
  5. Kolovrat v. OregonSupreme Court of the United States · 1961

15 more not listed; retrieve them via the Exa API.

3Cited by10 opinions

  1. Crow v. CommissionerUnited States Tax Court · 1985
  2. Mamula v. CommissionerUnited States Tax Court · 1964
  3. C'De Baca v. CommissionerUnited States Tax Court · 1962
  4. Dougherty v. CommissionerUnited States Tax Court · 1974
  5. Bhutta v. Comm'rUnited States Tax Court · 2015

5 more not listed; retrieve them via the Exa API.

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