Legal Opinion
Clifford A. Abrahamsen & Sole K. Abrahamsen v. Commissioner
United States Tax Court
Decided June 9, 2014No. 20466-11Published
1Opinion of the Court
142 T.C. No. 22
UNITED STATES TAX COURT CLIFFORD A. ABRAHAMSEN AND SOLE K. ABRAHAMSEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20466-11. Filed June 9, 2014. I.R.C. sec. 893 excludes from gross income and exempts from taxation income received by an employee of a foreign government or international organization if certain conditions are met. The I.R.C. sec. 893 exemption can be waived, and it must be waived by a person who wishes to become a permanent resident of the United States. The exemption does not apply to income received by a permanent resident after filing…
2Cases cited12 opinions
- Dahlstrom v. CommissionerUnited States Tax Court · 1985
- FPL Group, Inc. v. CommissionerUnited States Tax Court · 2001
- Elec. Arts, Inc. v. Comm'rUnited States Tax Court · 2002
- City of New York v. Permanent Mission of India to the United NationsCourt of Appeals for the Second Circuit · 2010
- United States v. CoplonDistrict Court, S.D. New York · 1949
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