Foley v. Commissioner
United States Tax Court
Petitioner, a U.S. citizen, resided and worked in West Berlin, Germany. He received incentive payments pursuant to art. 28 of the Berlin Promotion Law. Held, petitioner properly computed his foreign tax credit, for U.S. income tax purposes, without taking such payments into account. Held, further, such incentive payments are includable in income under sec. 61, I.R.C. 1954.
1Opinion of the Court
OPINION
JACOBS, Judge-.
Respondent determined the following deficiencies in petitioner’s Federal income taxes:
Taxable year Deficiency
1978 . $750
1979 . 6,854
1980. 4,563
This case was submitted pursuant to Rule 122.1 Pursuant to the Court’s direction, a supplemental stipulation of facts was filed. At the time the supplemental stipulation of facts was filed, the Court permitted respondent to file an amendment to answer seeking additional deficiencies for 1978, 1979, and 1980 in the amounts of $1,254, $77, and $2,646, respectively, making the total amount in controversy $2,004 for 1978, $6,931 for…
2Cases cited4 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Filler v. CommissionerUnited States Tax Court · 1980
- Crerar v. CommissionerUnited States Tax Court · 1956
3Cited by2 opinions
- Charles v. CommissionerUnited States Tax Court · 1991
- Foley v. CommissionerUnited States Tax Court · 1986