Cooper v. Commissioner
United States Tax Court
1. Petitioner, a citizen and resident of London, England, came to the United States on a temporary visa as a visitor in 1940. Her principal reason for coming was to escape the bombing dangers in London at that time. In 1941, she visited Mexico and in the same year returned to the United States as a quota immigrant. She remained in the United States until the war's end in 1945, when she returned to England where she has since resided.
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1. Petitioner, a citizen and resident of London, England, came to the United States on a temporary visa as a visitor in 1940. Her principal reason for coming was to escape the bombing dangers in London at that time. In 1941, she visited Mexico and in the same year returned to the United States as a quota immigrant. She remained in the United States until the war's end in 1945, when she returned to England where she has since resided. Held, that during the taxable years 1942, 1943, and 1944, petitioner was a resident alien in the United States and is taxable as such. 2. In the years 1942,…
1Opinion of the Court
OPINION.
Black, .Judge:
The questions which we have for decision in this proceeding are as follows:
1. Was the petitioner a resident of the United States during 1942, 1943, and 1944?
2. Is petitioner taxable upon dividends and salary unconditionally credited to her account in England in British pounds which she did not receive in the United States during the taxable years because of British Exchange Control Regulations?
3. If question No. 2 is answered in the affirmative, then should her taxable income be measured by the official exchange rate of the British pound or should it be measured by the…
2Cases cited7 opinions
- Mills v. CommissionerUnited States Tax Court · 1948
- Baehre v. CommissionerUnited States Tax Court · 1950
- Fry v. CommissionerUnited States Tax Court · 1947
- Foundation Co. v. CommissionerUnited States Tax Court · 1950
- Landau v. CommissionerUnited States Tax Court · 1946
2 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Durovic v. CommissionerUnited States Tax Court · 1970
- Marko Durovic v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1973
- Nelson v. CommissionerUnited States Tax Court · 1958
- Brittingham v. CommissionerUnited States Tax Court · 1976
- Marsman v. CommissionerUnited States Tax Court · 1952
21 more not listed; retrieve them via the Exa API.