STIERHOUT v. COMMISSIONER

Docket No. 48832.

24 T.C. 483 (1955)

LOIS KAISER STIERHOUT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 24, 1955.


Attorney(s) appearing for the Case

Sidney Pepper, Esq., for the petitioner.

James J. Quinn, Esq., for the respondent.


This proceeding involves a deficiency in income tax for the year 1947 in the amount of $483. Two questions are raised: Whether a deficiency may be claimed for a year for which the respondent has previously refunded taxes paid principally by withholding; and whether the petitioner was a bona fide resident of a foreign country in 1947 and thus exempt from income taxes under section 116 (a) of the Internal Revenue Code of 1939.

FINDINGS OF FACT.

The petitioner...

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