Nelson v. Commissioner
United States Tax Court
Petitioner was offered and accepted employment in Ethiopia on a project which was expected to last approximately 15 or 20 years. He left the United States on November 21, 1951, and arrived 7 days later in Paris, France, to take care of certain matters preliminary to proceeding to Ethiopia.
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Petitioner was offered and accepted employment in Ethiopia on a project which was expected to last approximately 15 or 20 years. He left the United States on November 21, 1951, and arrived 7 days later in Paris, France, to take care of certain matters preliminary to proceeding to Ethiopia. Unexpected difficulties arose, keeping petitioner from proceeding to Ethiopia until March 2, 1952. Thereafter, unforeseen problems made it impossible to continue with the project, and petitioner returned to the United States on March 13, 1953. Petitioner is a calendar year taxpayer. Held, on the facts,…
1Opinion of the Court
ForeesteR, Judge:
The Commissioner has determined deficiencies in the income tax of petitioners for their taxable years 1952 and 1953 in the respective amounts of $798.32 and $936.69. The sole issue is whether petitioners were bona fide residents of a foreign country or countries for a period which included an entire taxable year, within the purview of section 116 (a) (1) of the Internal Revenue Code of 1939, as amended by the Revenue Act of 1942.
FINDINGS OF FACT.
Some of the facts have been stipulated and are so found.
Petitioners, husband and wife, are citizens of the United States. They filed…
2Cases cited19 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Glenn Weible and Patricia Weible v. United StatesCourt of Appeals for the Ninth Circuit · 1957
- Johnson v. CommissionerUnited States Tax Court · 1946
- Downs v. CommissionerUnited States Tax Court · 1946
- Downs v. COMMISSIONER OF INTERNAL REVENUE.Court of Appeals for the Ninth Circuit · 1948
14 more not listed; retrieve them via the Exa API.
3Cited by49 opinions
- Howard J. Sochurek v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1962
- Dawson v. CommissionerUnited States Tax Court · 1972
- Sochurek v. CommissionerUnited States Tax Court · 1961
- Jellinek v. CommissionerUnited States Tax Court · 1961
- Nelson v. CommissionerUnited States Tax Court · 1998
44 more not listed; retrieve them via the Exa API.