Dowd v. Commissioner
United States Tax Court
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
- Lilly v. CommissionerSupreme Court of the United States · 1952
- Krichbaum v. United StatesDistrict Court, E.D. Tennessee · 1956
- Teskey v. CommissionerUnited States Tax Court · 1958
- Sverdrup v. CommissionerUnited States Tax Court · 1950
- George Y. Erlandson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
2 more not listed; retrieve them via the Exa API.