HANDFIELD v. COMMISSIONER

Docket No. 40251.

23 T.C. 633 (1955)

FRANK HANDFIELD, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 17, 1955.


Attorney(s) appearing for the Case

F. W. Oberkirch, C. P. A., for the petitioner.

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


This proceeding involves a deficiency in petitioner's income tax for the fiscal year ended July 31, 1949, in the amount of $639.67. The basic question is whether the petitioner, a nonresident alien, was engaged in business in the United States during the year in controversy. In the event that he was, there are further questions concerning whether he is entitled to charge off certain deductions against income earned in the United States.

Most of the facts have been...

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