Legal Opinion
Anne Moen Bullitt Biddle Brewster v. Commissioner of Internal Revenue
Court of Appeals for the D.C. Circuit
Decided July 3, 1979No. 77-2010PublishedCited by 70 opinions
1Opinion of the Court
Opinion PER CURIAM.
2Per curiam
A Tax Court decision upheld the Commissioner’s determination that there was a deficiency in appellant’s returns for the years 1962-65 and 1967-69 inclusive, and she appeals. The Commissioner based his determination upon section 911 of the Internal Revenue Code of 1954, 26 U.S.C. § 911 (1976). Section 911, which only applies to United States citizens who are bona fide residents of a foreign country, excludes from a taxpayer’s gross income certain amounts of “earned income” attributable to personal services performed abroad. It concomitantly disallows as deductions expenses…
3Cases cited21 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Helvering v. TaylorSupreme Court of the United States · 1935
- Doe v. McMillanSupreme Court of the United States · 1973
- Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- Hansford P. Miller v. Jackson AviromCourt of Appeals for the D.C. Circuit · 1967
16 more not listed; retrieve them via the Exa API.
4Cited by70 opinions
- Ralls Corp. v. Committee on Foreign Investment in the United StatesCourt of Appeals for the D.C. Circuit · 2014
- United States v. Carson, SamuelCourt of Appeals for the D.C. Circuit · 2006
- National Institute of Military Justice v. United States Department of DefenseCourt of Appeals for the D.C. Circuit · 2008
- Laffey v. Northwest Airlines, Inc.Court of Appeals for the D.C. Circuit · 1984
- Natl Mining Assn v. Fowler, JohnCourt of Appeals for the D.C. Circuit · 2003
65 more not listed; retrieve them via the Exa API.