LOVALD v. COMMISSIONER

Docket No. 26582.

16 T.C. 909 (1951)

RICHARD H. LOVALD, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 26, 1951.


Attorney(s) appearing for the Case

F. Trowbridge vom Baur, Esq., and Ralph E. Becker, Esq., for the petitioner.

James C. Maddox, Esq., for the respondent.


This case involves income taxes for the calendar years 1946 and 1947. Deficiencies were determined in the respective amounts of $1,076.89 and $1,199.36. The only question involved is whether the petitioner, a citizen of the United States, was a bona fide resident of a foreign country or countries during the 2 years, so that his income from sources without the United States was exempt from taxation under section 116 (a) (1) and (2) of the Internal Revenue Code.

FINDINGS...

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