Sochurek v. Commissioner
United States Tax Court
Petitioner, a foreign correspondent for Life magazine, maintained a base of operations in the Crown Colony of Singapore from November 1953 through December 1955, while covering news events throughout all of southeast Asia. During the taxable year in question, 1954, he spent only about 25 days in Singapore and the remainder of that year in various countries of the Far East on story assignments and in the United States because of family illness and vacation.
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Petitioner, a foreign correspondent for Life magazine, maintained a base of operations in the Crown Colony of Singapore from November 1953 through December 1955, while covering news events throughout all of southeast Asia. During the taxable year in question, 1954, he spent only about 25 days in Singapore and the remainder of that year in various countries of the Far East on story assignments and in the United States because of family illness and vacation. Held, petitioner has not established that he was a bona fide resident of Singapore or of any other foreign country during the entire…
1Opinion of the Court
Fisher, Judge:
Respondent determined a deficiency in petitioner’s income tax for the year 1954 in the amount of $4,239.28.
The sole issue presented for our consideration is whether petitioner was a bona fide resident of the Crown Colony of Singapore or any other country of southeast Asia during the entire taxable year 1954 within the meaning of section 911(a) (1) of the Code of 1954.1
FINDINGS OF FACT.
Some of the facts are stipulated and, together with exhibits, are found as stipulated.
Howard J. Sochurek, hereinafter sometimes called petitioner, filed his Federal income tax return for the year…
2Cases cited18 opinions
- 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
- Swenson v. ThomasCourt of Appeals for the Fifth Circuit · 1947
13 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- Schoneberger v. CommissionerUnited States Tax Court · 1980
- Vento v. Director of Virgin Islands Bureau of Internal RevenueCourt of Appeals for the Third Circuit · 2013
- Bergersen v. CommissionerUnited States Tax Court · 1995
- Cobb v. CommissionerUnited States Tax Court · 1991
- Riley v. CommissionerUnited States Tax Court · 1980
27 more not listed; retrieve them via the Exa API.