Legal Opinion

Dowd v. Commissioner

United States Tax Court

Decided December 4, 1961No. Docket No. 84485Published

Petitioner was in Japan from October of 1955 until July of 1957 as a Fulbright lecturer at Kobe University. He was paid in inconvertible Japanese currency by the United States Educational Commission in Japan.

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Petitioner was in Japan from October of 1955 until July of 1957 as a Fulbright lecturer at Kobe University. He was paid in inconvertible Japanese currency by the United States Educational Commission in Japan. Held: 1. Amounts paid to petitioner in 1956 and 1957 as a Fulbright lecturer were "paid by the United States or an agency thereof" within the meaning of section 911(a)(2) of the 1954 Code and thus were not excludible from gross income. 2. Petitioner's tax residence remained in the United States during 1956 and 1957. As a Fulbright lecturer in Japan, petitioner was temporarily "away from…

1Opinion of the Court

Laurence P. Dowd and Juliet R. Dowd, Petitioners, v. Commissioner of Internal Revenue, Respondent

Dowd v. Commissioner

Docket No. 84485

United States Tax Court

37 T.C. 399; 1961 U.S. Tax Ct. LEXIS 18;

December 4, 1961, Filed

Decision will be entered under Rule 50.

Petitioner was in Japan from October of 1955 until July of 1957 as a Fulbright lecturer at Kobe University. He was paid in inconvertible Japanese currency by the United States Educational Commission in Japan. Held:

1. Amounts paid to petitioner in 1956 and 1957 as a Fulbright lecturer were "paid by the United States or an agency thereof"…

2Cases cited7 opinions

  1. Lilly v. CommissionerSupreme Court of the United States · 1952
  2. Krichbaum v. United StatesDistrict Court, E.D. Tennessee · 1956
  3. Teskey v. CommissionerUnited States Tax Court · 1958
  4. Sverdrup v. CommissionerUnited States Tax Court · 1950
  5. George Y. Erlandson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960

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