Legal Opinion

Maestre v. Commissioner

United States Tax Court

Decided November 26, 1979No. Docket No. 8674-78PublishedCited by 2 opinions

Petitioners, citizens of the United States residing in Puerto Rico, received compensation for services rendered to the Veterans' Administration, an agency of the United States Government. Held, sec. 933(1), I.R.C. 1954, validly taxes income earned by a bona fide Puerto Rican resident as an employee of an agency of the United States Government and does not violate the "Compact" between Puerto Rico and the United States.

1Opinion of the Court

OPINION

Featherston, Judge:

Respondent determined a deficiency in the amount of $378.43 in petitioners’ Federal income taxes for 1975. The only issue for decision is whether, under section 933,1 petitioners must include in gross income amounts received for services rendered to the Veterans’ Administration by petitioner Ada N. Maestre, a citizen of the United States and a bona fide resident of Puerto Rico.

All the facts have been stipulated. The stipulation of facts, together with the exhibits attached thereto, are incorporated herein by this reference.

Petitioners Ada N. Maestre (hereinafter Ada)…

2Cases cited10 opinions

  1. Cook v. TaitSupreme Court of the United States · 1924
  2. United States v. ValentineDistrict Court, D. Puerto Rico · 1968
  3. Liquilux Gas Services of Ponce, Inc. v. Tropical Gas CompanyDistrict Court, D. Puerto Rico · 1969
  4. United States v. RexachDistrict Court, D. Puerto Rico · 1960
  5. Roque v. CommissionerUnited States Tax Court · 1976

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3Cited by2 opinions

  1. Maestre v. CommissionerUnited States Tax Court · 1979
  2. Young v. CommissionerUnited States Tax Court · 1983

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