Angerhofer v. Commissioner
United States Tax Court
Petitioners were citizens and domiciliaries of West Germany in the taxable years at issue. During those years, I.B.M. in New York employed petitioner-husbands and paid their wages. Held: Under the applicable laws of West Germany, petitioner-husbands' U.S. earnings were not community property, and petitioner-wives did not have present vested interests in the earnings.
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Petitioners were citizens and domiciliaries of West Germany in the taxable years at issue. During those years, I.B.M. in New York employed petitioner-husbands and paid their wages. Held: Under the applicable laws of West Germany, petitioner-husbands' U.S. earnings were not community property, and petitioner-wives did not have present vested interests in the earnings. Accordingly, under sec. 1, I.R.C. 1954, petitioner-husbands must include in taxable income the full amount of their earnings while employed in the United States.
1Opinion of the Court
Otto A. Angerhofer, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Angerhofer v. Commissioner
Docket Nos. 22182-83, 17013-84, 17014-84, 26793-84, 40702-84, 40703-84, 5812-85
United States Tax Court
87 T.C. 814; 1986 U.S. Tax Ct. LEXIS 36; 87 T.C. No. 51;
October 21, 1986, Filed
Decisions will be entered under Rule 155.
Petitioners were citizens and domiciliaries of West Germany in the taxable years at issue. During those years, I.B.M. in New York employed petitioner-husbands and paid their wages. Held: Under the applicable laws of West Germany, petitioner-husbands' U.S.…
2Cases cited13 opinions
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Poe v. SeabornSupreme Court of the United States · 1930
- United States v. DavisSupreme Court of the United States · 1962
- Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
- Hopkins v. BaconSupreme Court of the United States · 1930
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