Ferrer v. Commissioner
United States Tax Court
Held, on the facts, petitioner was not a bona fide resident of a foreign country or countries for an uninterrupted period which includes an entire taxable year for the purposes of sec. 911(a)(1), I.R.C. 1954. Held, further, petitioner is entitled to a deduction under sec. 162(a)(1) for certain secretarial expenses. Held, further, as to other deductions claimed by petitioner, he has failed to meet his burden of proof.
1Opinion of the Court
Fat, Judge:
Respondent determined a deficiency in petitioner’s Federal income tax for the calendar year 1962 in the amount of $122,-840.18. The issues presented for determination are: (1) Whether $205,-840.03 of the salaries received by the petitioner during 1962 is exempt from taxation under section 911(a) (1) of the Internal Revenue Code of 1954; and (2) if such income is not exempt, whether petitioner’s unreimbursed business expenses applicable to this income entitle petitioner to a deduction in excess of the amount allowed by the respondent.
FINDINGS OF FACT
Some of tlie facts have been…
2Cases cited4 opinions
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Nelson v. CommissionerUnited States Tax Court · 1958
- Jellinek v. CommissionerUnited States Tax Court · 1961
- McCurnin v. CommissionerUnited States Tax Court · 1958
3Cited by17 opinions
- Dillin v. CommissionerUnited States Tax Court · 1971
- Rice v. CommissionerUnited States Tax Court · 1994
- Robertson v. CommissionerUnited States Tax Court · 2000
- Cahill v. Comm'rUnited States Tax Court · 2013
- Fingar v. CommissionerUnited States Tax Court · 1997
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