Friedman v. Commissioner
United States Tax Court
1. Petitioner, formerly a citizen of France, came to the United States in 1950 and established a residence in New York City. In April 1952 she departed for French Morocco under an overseas employment contract with a firm which was constructing a project there on behalf of the United States Government.
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1. Petitioner, formerly a citizen of France, came to the United States in 1950 and established a residence in New York City. In April 1952 she departed for French Morocco under an overseas employment contract with a firm which was constructing a project there on behalf of the United States Government. Prior to her departure, petitioner applied for and received a permit from the Immigration and Naturalization Service to reenter the United States as a nonquota immigrant at any time within 1 year. Prior to the expiration of this permit on January 7, 1953, she applied for and received an…
1Opinion of the Court
FisheR, Judge:
Respondent determined deficiencies in petitioner’s income tax for the taxable years 1952 and 1958 in the respective amounts of $684.77 and $906.
The issues presented for our consideration are: (1) Whether petitioner was a resident or nonresident alien of the United States during the taxable years 1952 and 1953 within the meaning of section 211 of the Code of 1939; and (2) if petitioner was a resident alien of the United States during said years, whether funds expended by her for transportation, meals, lodging, tips, and miscellaneous expenses are deductible as expenses of travel,…
2Cases cited23 opinions
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Peurifoy v. CommissionerSupreme Court of the United States · 1958
- Commissioner of Internal Revenue v. James E. Peurifoy, Paul v. Stines and Betty O. Stines, John S. Hall and Doris D. HallCourt of Appeals for the Fourth Circuit · 1958
- Johnson v. CommissionerUnited States Tax Court · 1946
- Barnhill v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1945
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3Cited by37 opinions
- Michaels v. CommissionerUnited States Tax Court · 1969
- Commissioner v. StidgerSupreme Court of the United States · 1967
- Norwood v. CommissionerUnited States Tax Court · 1976
- Adams v. CommissionerUnited States Tax Court · 1966
- Lemery v. CommissionerUnited States Tax Court · 1970
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