Newman v. Comm'r
United States Tax Court
Ps were foreign citizens who worked in the United States at foreign embassies whose countries had not been certified by the U.S. State Department under I.R.C. sec. 893(b). Claiming tax exemption for those wages pursuant to I.R.C. sec. 893(a), Ps did not report their embassy wages as income. R issued notices of deficiency including the embassy wages as income, and Ps filed petitions.
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Ps were foreign citizens who worked in the United States at foreign embassies whose countries had not been certified by the U.S. State Department under I.R.C. sec. 893(b). Claiming tax exemption for those wages pursuant to I.R.C. sec. 893(a), Ps did not report their embassy wages as income. R issued notices of deficiency including the embassy wages as income, and Ps filed petitions. Before trial of these cases, this Court issued its Opinion in Abdel-Fattah v. Commissioner, 134 T.C. 190 (2010), holding against the IRS's interpretation of I.R.C. sec. 893(b). As to Ps, the IRS later conceded the…
1Opinion of the Court
MARITZA FURIATTI NEWMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent; ROBERT MECK COMFORT AND OSCARLINA CAMPOS COMFORT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Newman v. Comm'r
Docket Nos. 25028-09, 1124-10.
United States Tax Court
T.C. Memo 2012-74; 2012 Tax Ct. Memo LEXIS 73; 103 T.C.M. (CCH) 1398;
March 19, 2012, Filed
Appropriate orders and decisions will be entered.
Ps were foreign citizens who worked in the United States at foreign embassies whose countries had not been certified by the U.S. State Department under I.R.C. sec. 893(b). Claiming tax exemption…
2Cases cited26 opinions
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3Cited by2 opinions
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