Ory Eshel & Linda Coryell Eshel v. Commissioner

142 T.C. No. 11

UNITED STATES TAX COURT ORY ESHEL AND LINDA CORYELL ESHEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8055-12. Filed April 2, 2014. In 1987, the United States and France entered into a Totalization Agreement to coordinate benefits under their respective social security systems. Section 317(b)(4) of the Social Security Amendments of 1977 (SSA),

Pub. L. No. 95-216, 91

Stat. at 1540, provides that, notwithstanding any other provision of law, taxes paid by an individual to a foreign country “in accordance with the terms of” a totalization agreement shall…