Flanagan v. Commissioner
United States Tax Court
Pension payments received in 1944 and 1945 attributable to compensation of United States citizen for services rendered during more than 2 years' previous residence abroad but received after taxable year of change of residence to the United Statesheld not exempt under Internal Revenue Code, section 116 (a) (2). Wood v. United States, 104 F. Supp. 1020, followed.
1Opinion of the Court
Estate of James W. Flanagan, Deceased, J. Albert DeCamp, Henry F. Pelkey and City Bank Farmers Trust Company, Executors, Petitioner, v. Commissioner of Internal Revenue, Respondent
Flanagan v. Commissioner
Docket No. 35722
United States Tax Court
18 T.C. 1241; 1952 U.S. Tax Ct. LEXIS 83;
September 30, 1952, Promulgated
Decision will be entered under Rule 50.
Pension payments received in 1944 and 1945 attributable to compensation of United States citizen for services rendered during more than 2 years' previous residence abroad but received after taxable year of change of residence to the United…
2Cases cited5 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Takao Ozawa v. United StatesSupreme Court of the United States · 1922
- Baehre v. CommissionerUnited States Tax Court · 1950
- Wood v. United StatesUnited States Court of Claims · 1952
- Flanagan v. CommissionerUnited States Tax Court · 1952