[DOWNLOAD] "Marsman v. Commissioner of Internal Revenue." by United States Court of Appeals ~ Book PDF Kindle ePub Free

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eBook details

• Title: Marsman v. Commissioner of Internal Revenue.
• Author : United States Court of Appeals
• Release Date : January 03, 1953
• Genre: Law,Books,Professional & Technical,
• Pages : * pages
• Size : 69 KB

Description

This petition to review the decision of the Tax Court presents the questions whether Mary A. Marsman, a citizen of the Commonwealth of the Philippines, was a resident of the United States during the period from September 22, 1940 to December 31, 1941, and if so, whether she is liable for United States income tax on certain undistributed net income held on December 31, 1940 by La Trafagona, a Philippine corporation, wholly owned by her. If these questions are resolved against the taxpayer, it is also necessary to determine (1) whether the tax should be based on one-half of the entire amount of the undistributed income of La Trafagona on December 31, 1940, or only so much thereof as was acquired after September 22, 1940, when she became a resident of the United States; and (2) whether the taxpayer, being on a cash basis, is entitled to a credit against her United States income tax for 1941 in the amount of the income taxes paid by her to the Philippine Islands in 1941 for the years 1938 and 1940.

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