Legal Opinion

Zaffaroni v. Commissioner

United States Tax Court

Decided February 17, 1976No. Docket Nos. 9279-72, 9280-72Published

Petitioners are citizens of Uruguay, where they were married, and were domiciled in Mexico during the taxable years 1958 through 1961. The husband earned a salary in excess of $ 3,000 in each of the taxable years from United States sources. He also carried out numerous stock exchange transactions in New York in 1959, 1960, and 1961, from which substantial capital gains were realized.

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Petitioners are citizens of Uruguay, where they were married, and were domiciled in Mexico during the taxable years 1958 through 1961. The husband earned a salary in excess of $ 3,000 in each of the taxable years from United States sources. He also carried out numerous stock exchange transactions in New York in 1959, 1960, and 1961, from which substantial capital gains were realized. Held, both the salary and the capital gains were community income under the applicable laws of Mexico. Held, further, the wife's community share of both the salary and the capital gains is taxable to her under…

1Opinion of the Court

Alejandro Zaffaroni, Petitioner v. Commissioner of Internal Revenue, Respondent; Lyda Zaffaroni, Petitioner v. Commissioner of Internal Revenue, Respondent

Zaffaroni v. Commissioner

Docket Nos. 9279-72, 9280-72

United States Tax Court

65 T.C. 982; 1976 U.S. Tax Ct. LEXIS 156;

February 17, 1976, Filed

Decisions will be entered under Rule 155.

Petitioners are citizens of Uruguay, where they were married, and were domiciled in Mexico during the taxable years 1958 through 1961. The husband earned a salary in excess of $ 3,000 in each of the taxable years from United States sources. He also carried out…

2Cases cited31 opinions

  1. Poe v. SeabornSupreme Court of the United States · 1930
  2. United States v. MitchellSupreme Court of the United States · 1971
  3. United States v. MalcolmSupreme Court of the United States · 1931
  4. Bender v. PfaffSupreme Court of the United States · 1930
  5. In re the Estate of CrichtonNew York Court of Appeals · 1967

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