Ying v. Commissioner
United States Tax Court
Petitioners, husband and wife, were employed during the years in issue by the United Nations and UNICEF. Husband is a citizen of Jamaica and wife is a citizen of the Republic of the Philippines. Both petitioners had become permanent residents of the United States and, as acondition for obtaining such status, both of them had filed U.S.
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Petitioners, husband and wife, were employed during the years in issue by the United Nations and UNICEF. Husband is a citizen of Jamaica and wife is a citizen of the Republic of the Philippines. Both petitioners had become permanent residents of the United States and, as acondition for obtaining such status, both of them had filed U.S. Department of Justice Immigration and Naturalization Service Form I-508A, "Waiver of Rights, Privileges, Exemptions and Immunities (Under Section 247(b) of the Immigration and Nationality Act)". Petitioners claim eligibility under sec. 893(a), I.R.C., to…
1Opinion of the Court
OPINION
Whalen, Judge:
This case is before the Court to decide petitioners’ motion for summary judgment and respondent’s amended cross-motion for partial summary judgment. The sole issue raised in petitioners’ motion is whether the salaries and wages which they received from the United Nations and UNICEF during the years in issue are exempt from Federal income tax under section 893. Unless otherwise stated, all section references are to the Internal Revenue Code. In respondent’s cross-motion for partial summary judgment, the Commissioner asserts that petitioners’ salaries and wages are “subject…
2Cases cited9 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Toibb v. RadloffSupreme Court of the United States · 1991
- Elkins v. MorenoSupreme Court of the United States · 1978
- Marshall v. CommissionerUnited States Tax Court · 1985
- Saxbe v. BustosSupreme Court of the United States · 1974
4 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Abdel-Fattah v. CommissionerUnited States Tax Court · 2010
- Abrahamsen v. Comm'rUnited States Tax Court · 2014
- Abrahamsen v. Comm'rUnited States Tax Court · 2014
- Clifford A. Abrahamsen & Sole K. Abrahamsen v. CommissionerUnited States Tax Court · 2014
- Clifford A. Abrahamsen & Sole K. Abrahamsen v. CommissionerUnited States Tax Court · 2014
1 more not listed; retrieve them via the Exa API.