Beaumont v. Commissioner
United States Board of Tax Appeals
1. Salaries received in 1926, 1927, and 1928 by the petitioner, a nonresident citizen, from domestric corporations held not exempt from taxation as earned income from sources without the United States, in the absence of proof that the petitioner actually performed services abroad for which the salaries were paid to him. 2. Bad debt deduction claimed by the petitioner in his return for 1926 is denied, since the evidence does not show that the debt was first ascertained to be…
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1. Salaries received in 1926, 1927, and 1928 by the petitioner, a nonresident citizen, from domestric corporations held not exempt from taxation as earned income from sources without the United States, in the absence of proof that the petitioner actually performed services abroad for which the salaries were paid to him. 2. Bad debt deduction claimed by the petitioner in his return for 1926 is denied, since the evidence does not show that the debt was first ascertained to be worthless in that year. 3. The deduction of losses resulting from gambling at Monte Carlo in 1926, 1927, and 1928…
1Opinion of the Court
*478OPINION.
Smith:
The principal issue in these proceedings is whether the salaries received by the petitioner from the Beaumont Investment Company, the Dayton Securities Company, the Beaumont Investment Trust, and the Commercial Investment Trust, Inc., in 1926,1927, and 1928, are exempt from taxation under the following provisions of the Revenue Acts of 1926 and 1928:
Section 213 of the Revenue Act of 1926:
For the purposes of this title, except as otherwise provided in section 233—
* * * * * * *(b) The term “ gross income ” does not include the following items, which shall be exempt from taxation…
2Cited by22 opinions
- Denver & R. G. W. R. Co. v. CommissionerUnited States Tax Court · 1959
- Perkins v. CommissionerUnited States Tax Court · 1963
- Humphrey v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1947
- Simms v. CommissionerUnited States Board of Tax Appeals · 1933
- Wagner v. CommissionerUnited States Board of Tax Appeals · 1934
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