Legal Opinion

Rosenberg v. Commissioner

United States Board of Tax Appeals

Decided February 8, 1928No. Docket No. 10086Published

1. The petitioner was an actual resident of the State of, new York during 1919 and 1920. Held, that he was not domiciled in Texas during the same years. 2. The petitioner filed on March 12, 1920, by his agent, an income-tax return for the calendar year 1919, reporting therein his individual income including community income, if any.

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1. The petitioner was an actual resident of the State of, new York during 1919 and 1920. Held, that he was not domiciled in Texas during the same years. 2. The petitioner filed on March 12, 1920, by his agent, an income-tax return for the calendar year 1919, reporting therein his individual income including community income, if any. The petitioner and his wife filed separate returns for the calendar year 1920. The income of the petitioner for both the years 1919 and 1920 was derived principally from a business carried on in New York State, a noncommunity-property State. The respondent…

1Opinion of the Court

LEE ROSENBERG, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Rosenberg v. Commissioner

Docket No. 10086.

United States Board of Tax Appeals

10 B.T.A. 601; 1928 BTA LEXIS 4067;

February 8, 1928, Promulgated

1. The petitioner was an actual resident of the State of, new York during 1919 and 1920. Held, that he was not domiciled in Texas during the same years.

2. The petitioner filed on March 12, 1920, by his agent, an income-tax return for the calendar year 1919, reporting therein his individual income including community income, if any. The petitioner and his wife filed separate returns…

2Cases cited4 opinions

  1. The Venus, Rae, MasterSupreme Court of the United States · 1814
  2. United States v. JorgensonDistrict Court, W.D. Michigan · 1916
  3. Johnson v. CommissionerUnited States Board of Tax Appeals · 1927
  4. Rosenberg v. CommissionerUnited States Board of Tax Appeals · 1928

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