Bouldin v. Commissioner
United States Tax Court
In 1942 petitioner, then a widower, went to Edmonton, Canada, as an employee of a contractor who was engaged in construction work on the Canol oil project. For years petitioner had suffered from a chronic sinus trouble. Owing to the dry climate in Edmonton, petitioner's health immediately improved and the relief was so great that sometime during the year 1942 he definitely determined to make his permanent residence in Edmonton.
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In 1942 petitioner, then a widower, went to Edmonton, Canada, as an employee of a contractor who was engaged in construction work on the Canol oil project. For years petitioner had suffered from a chronic sinus trouble. Owing to the dry climate in Edmonton, petitioner's health immediately improved and the relief was so great that sometime during the year 1942 he definitely determined to make his permanent residence in Edmonton. Petitioner has made proof of acts and statements which establish his definite intention prior to 1943 to acquire a residence in Canada and has shown that his stay in…
1Opinion of the Court
OPINION.
Black, Judge:
In this proceeding there is no dispute but that petitioner was physically present in Canada during the entire year of 1943, that the $16,790.08 paid to him by his employers was earned income under section 25 (a) of the Internal Revenue Code, and that the amounts weré not paid by the United States or any agency thereof. Thus we have only one issue to determine, and that is whether petitioner was a bona fide resident of Canada during the entire taxable year 1943. The applicable statute is section 116 (a) (1) of the Internal Revenue Code.1
Section 29.116-1, Regulations 111,…
2Cases cited3 opinions
- Johnson v. CommissionerUnited States Tax Court · 1946
- Downs v. CommissionerUnited States Tax Court · 1946
- Baer v. CommissionerUnited States Tax Court · 1946
3Cited by25 opinions
- Howard J. Sochurek v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1962
- Nelson v. CommissionerUnited States Tax Court · 1958
- Baehre v. CommissionerUnited States Tax Court · 1950
- Myers v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1950
- Sverdrup v. CommissionerUnited States Tax Court · 1950
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