Legal Opinion

Perkins v. Commissioner

United States Tax Court

Decided May 17, 1963No. Docket No. 92941Published

1. Petitioner is a United States citizen who was, for the year 1958 and a number of years prior thereto, a bona fide resident of Italy. 2. Income received by petitioner in 1958 from an estate of her deceased husband, which estate was being administered in New Jersey, is taxable to petitioner and is not excluded from United States income taxes under the provisions of the tax convention between the United States and Italy. 3. Executrix and trustee commissions received by…

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1. Petitioner is a United States citizen who was, for the year 1958 and a number of years prior thereto, a bona fide resident of Italy. 2. Income received by petitioner in 1958 from an estate of her deceased husband, which estate was being administered in New Jersey, is taxable to petitioner and is not excluded from United States income taxes under the provisions of the tax convention between the United States and Italy. 3. Executrix and trustee commissions received by petitioner in 1958 pursuant to order of the Probate Court of Bergen County, New Jersey, for serving as an executrix of her…

1Opinion of the Court

Irene Vavasour Elder Perkins, Petitioner, v. Commissioner of Internal Revenue, Respondent

Perkins v. Commissioner

Docket No. 92941

United States Tax Court

40 T.C. 330; 1963 U.S. Tax Ct. LEXIS 119;

May 17, 1963, Filed

Decision will be entered under Rule 50.

1. Petitioner is a United States citizen who was, for the year 1958 and a number of years prior thereto, a bona fide resident of Italy.

2. Income received by petitioner in 1958 from an estate of her deceased husband, which estate was being administered in New Jersey, is taxable to petitioner and is not excluded from United States income taxes under…

2Cases cited20 opinions

  1. Anna J. McDowell v. Abraham A. Ribicoff, Secretary of Health, Welfare and EducationCourt of Appeals for the Third Circuit · 1961
  2. Lewenhaupt v. CommissionerUnited States Tax Court · 1953
  3. Perkins v. CommissionerUnited States Tax Court · 1963
  4. Jan Casimir Lewenhaupt v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
  5. Beaumont v. CommissionerUnited States Board of Tax Appeals · 1932

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