Legal Opinion

Dillin v. Commissioner

United States Tax Court

Decided May 6, 1971No. Docket Nos. 5050-67, 5051-67PublishedCited by 45 opinions

Prior to September 1963, petitioners, husband and wife, were both U.S. citizens and resident-domiciliaries of Texas. During 1958 H performed certain services. By agreement entered into with S corporation in July 1958, he was compensated for these services and received payments in 1963, 1964, and 1965. In September 1963, shortly before he received the first payment, H renounced his U.S. citizenship and became a resident of the Bahamas.

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Prior to September 1963, petitioners, husband and wife, were both U.S. citizens and resident-domiciliaries of Texas. During 1958 H performed certain services. By agreement entered into with S corporation in July 1958, he was compensated for these services and received payments in 1963, 1964, and 1965. In September 1963, shortly before he received the first payment, H renounced his U.S. citizenship and became a resident of the Bahamas. W accompanied him to the Bahamas but retained her U.S. citizenship. Held, despite the fact that H was a U.S. citizen when he earned the amounts in question he…

1Opinion of the Court

Sterkett, Judge:

Respondent in bis notices of jeopardy assessments determined deficiencies and additions to tax, under sections 6651(a) and 6653 (a), I.R.C. 1954,2 as follows:

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Altbougb there is one basic issue for decision, the respondent’s determination presents several different questions: (1) Whether petitioner William N. Dillin was taxable on certain amounts because he was a U.S. citizen at the time he engaged in the activity which gave rise to the pertinent payments; (2) if the answer to the first question is negative, whether petitioner William N. Dillin was a nonresident…

2Cases cited23 opinions

  1. Poe v. SeabornSupreme Court of the United States · 1930
  2. Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
  3. Marcello v. CommissionerUnited States Tax Court · 1964
  4. Hopkins v. BaconSupreme Court of the United States · 1930
  5. Cook v. TaitSupreme Court of the United States · 1924

18 more not listed; retrieve them via the Exa API.

3Cited by45 opinions

  1. United States v. MitchellSupreme Court of the United States · 1971
  2. Pessin v. CommissionerUnited States Tax Court · 1972
  3. Crow v. CommissionerUnited States Tax Court · 1985
  4. Stemkowski v. CommissionerUnited States Tax Court · 1981
  5. Francisco v. Comm'rUnited States Tax Court · 2002

40 more not listed; retrieve them via the Exa API.

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