Donaldson v. Commissioner
United States Tax Court
During 1963 petitioner was employed by the American Embassy Cooperative Commissary in Pakistan. The commissary was organized and operated under Government regulations; policy and management direction of the commissary was vested in the State Department; and the commissary was engaged in governmental functions and had no commercial objectives.
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During 1963 petitioner was employed by the American Embassy Cooperative Commissary in Pakistan. The commissary was organized and operated under Government regulations; policy and management direction of the commissary was vested in the State Department; and the commissary was engaged in governmental functions and had no commercial objectives. Held, the commissary was an agency of the United States for the purpose of sec. 911(a), I.R.C. 1954, and, consequently, petitioner is not entitled to exclude from his gross income the compensation he received therefrom.
1Opinion of the Court
Feathekston, Judge:
Respondent determined a deficiency in petitioners’ joint Federal income tax for 1963 in the amount of $2,136.56. The only issue for decision is whether the compensation received by petitioner Cecil A. Donaldson during 1963 from the American Embassy Cooperative Commissary in Pakistan was paid by an agency of the United States, and hence was not excludable from petitioners’ gross income under section 911 (a). 1
FINDINGS OF FACT
Cecil A. Donaldson (hereinafter referred to as petitioner) and Liselotte Donaldson, husband and wife, are citizens of the United States who were…
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- Swenson v. ThomasCourt of Appeals for the Fifth Circuit · 1947
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