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BREWSTER v. C. I. R.

No. 77-2010.

607 F.2d 1369 (1979)

Anne Moen Bullitt Biddle BREWSTER, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided June 1, 1979.

As Amended July 3, 1979.

Attorney(s) appearing for the Case

Michael Mulroney, Washington, D. C., with whom Thomas E. Jenks, Washington, D. C., was on the brief, for appellant.

Gilbert S. Rothenberg, Atty., Dept. of Justice, Washington, D. C., with whom M. Carr Ferguson, Asst. Atty. Gen., and Gary R. Allen, Atty., Dept. of Justice, Washington, D. C., were on the brief, for appellee.

Stuart E. Seigel, Atty., Internal Revenue Service, Washington, D. C., entered an appearance for appellee.

Before MacKINNON and ROBB, Circuit Judges, and RICHEY, United States District Judge for the United States District Court for the District of Columbia.

Opinion PER CURIAM.

PER CURIAM:

A Tax Court decision upheld the Commissioner's determination that there was a deficiency in appellant's returns for the years 1962-65 and 1967-69 inclusive, and she appeals. The Commissioner based his determination upon section 911 of the Internal Revenue Code of 1954, 26 U.S.C. § 911 (1976). Section 911, which only applies to United States citizens who are bona fide residents of a foreign country, excludes from...

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