Craig v. Commissioner
United States Tax Court
Held, P, a bona fide resident of Switzerland since 1968, abandoned his Swiss residence on May 12, 1974, when he and his family severed all community ties, took all their possessions, and left for the United States with the definite intention of not returning. Therefore, under sec. 911, I.R.C. 1954, as amended, Ps are entitled to exclude, as earned income from sources outside the United States, $ 8,973 from their gross income for 1974.
1Opinion of the Court
Raymond A. Craig and Norma F. Craig, Petitioners v. Commissioner of Internal Revenue, Respondent
Craig v. Commissioner
Docket No. 11403-78
United States Tax Court
73 T.C. 1034; 1980 U.S. Tax Ct. LEXIS 173;
March 6, 1980, Filed
Decision will be entered for the petitioners.
Held, P, a bona fide resident of Switzerland since 1968, abandoned his Swiss residence on May 12, 1974, when he and his family severed all community ties, took all their possessions, and left for the United States with the definite intention of not returning. Therefore, under sec. 911, I.R.C. 1954, as amended, Ps are entitled to…
2Cases cited9 opinions
- Adams v. CommissionerUnited States Tax Court · 1966
- Dillin v. CommissionerUnited States Tax Court · 1971
- Friedman v. CommissionerUnited States Tax Court · 1961
- Seeley v. Commissioner of Internal Revenue. Seeley v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1951
- Baer v. CommissionerUnited States Tax Court · 1946
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