Anne Moen Bullitt Brewster v. Commissioner of Internal Revenue

Taxpayer, a citizen of the United States, was a bona fide resident during the taxable years 1956-1960 of Ireland, where she engaged in the business of farming, raising cattle, and breeding, training and racing horses, in which both her personal services and capital were income-producing factors. She is therefore governed by Section 911 of the Internal Revenue Code of 1954, relating to earned income from sources without the United States. 1

The gross income taxpayer received in Ireland from her farming business was exceeded each year by the farm expenses incurred there, resulting in a net farm…