Legal Opinion

Robida v. Commissioner

United States Tax Court

Decided April 15, 1970No. Docket No. 4861-62UnpublishedCited by 3 opinions

Held: Income derived from taxpayer's manipulation of slot machines located abroad constitutes "earned income" within the meaning of section 911(b), I.R.C. 1954, and is excludable from gross income and exempt from taxation under section 911(a)(2), the other facts necessary to qualify this income for exclusion under section 911(a)(2), being shown.

1Opinion of the Court

Daniel A. Robida v. Commissioner.

Robida v. Commissioner

Docket No. 4861-62.

United States Tax Court

T.C. Memo 1970-86; 1970 Tax Ct. Memo LEXIS 274; 29 T.C.M. (CCH) 407; T.C.M. (RIA) 70086;

April 15, 1970, Filed

Held: Income derived from taxpayer's manipulation of slot machines located abroad constitutes "earned income" within the meaning of section 911(b), I.R.C. 1954, and is excludable from gross income and exempt from taxation under section 911(a)(2), the other facts necessary to qualify this income for exclusion under section 911(a)(2), being shown.

John R. Swendsen, for the petitioner. Eugene…

2Cases cited1 opinion

  1. Daniel A. Robida v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1967

3Cited by3 opinions

  1. Kramer v. Comm'rUnited States Tax Court · 1983
  2. Jones v. CommissionerUnited States Tax Court · 1979
  3. Kramer v. Comm'rUnited States Tax Court · 1983

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