Perkins v. Commissioner
United States Tax Court
1. Petitioner is a United States citizen who was, for the year 1958 and a number of years prior thereto, a bona fide resident of Italy. 2. Income received by petitioner in 1958 from an estate of her deceased husband, which estate was being administered in New Jersey, is taxable to petitioner and is not excluded from United States income taxes under the provisions of the tax convention between the United States and Italy. 3. Executrix and trustee commissions received by…
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1. Petitioner is a United States citizen who was, for the year 1958 and a number of years prior thereto, a bona fide resident of Italy. 2. Income received by petitioner in 1958 from an estate of her deceased husband, which estate was being administered in New Jersey, is taxable to petitioner and is not excluded from United States income taxes under the provisions of the tax convention between the United States and Italy. 3. Executrix and trustee commissions received by petitioner in 1958 pursuant to order of the Probate Court of Bergen County, New Jersey, for serving as an executrix of her…
1Opinion of the Court
Scott, Judge:
Respondent determined a deficiency in petitioner’s income tax for tlie year 1958 in the amount of $1,836.45.
The issues for decision are:(1) Whether the amount of $6,600 received in 1958 by petitioner from a trust created in her husband’s will is includable in her gross income in computing her U.S. Federal income tax or is exempt from such tax under the provisions of article X of the convention between the United States of America and the Italian Republic.(2) Whether commissions received by petitioner in 1958 as coexecu-trix and cotrustee of the New Jersey estate of her deceased…
2Cases cited18 opinions
- Anna J. McDowell v. Abraham A. Ribicoff, Secretary of Health, Welfare and EducationCourt of Appeals for the Third Circuit · 1961
- Lewenhaupt v. CommissionerUnited States Tax Court · 1953
- Jan Casimir Lewenhaupt v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
- Beaumont v. CommissionerUnited States Board of Tax Appeals · 1932
- Beaumont v. HelveringCourt of Appeals for the D.C. Circuit · 1934
13 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Snyder v. CommissionerUnited States Tax Court · 1989
- Schoneberger v. CommissionerUnited States Tax Court · 1980
- Stemkowski v. CommissionerUnited States Tax Court · 1981
- Estate of Arthur Chase Shafer, Deceased, Chase Shafer, Co-Executor, and Resor Shafer, Co-Executor v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1984
- Filler v. CommissionerUnited States Tax Court · 1980
24 more not listed; retrieve them via the Exa API.