Jose v. Ferrer v. Commissioner of Internal Revenue

Second Circuit

Jose v. Ferrer v. Commissioner of Internal Revenue

409 F.2d 1359

CourtCourt of Appeals for the Second Circuit

DecidedMay 20, 1969

Docket19-1724

StatusPublished

This text of 409 F.2d 1359 (Jose v. Ferrer v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Jose v. Ferrer v. Commissioner of Internal Revenue, 409 F.2d 1359 (2d Cir. 1969).

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Opinion

409 F.2d 1359

69-1 USTC P 9425

Jose V. FERRER, Petitioner-Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

No. 527, Docket 32888.

United States Court of Appeals Second Circuit.

Argued May 20, 1969.
Decided May 20, 1969.

Timothy P. Walsh, New York City (Hardin, Hess, Eder & Rashap, New York City, on the brief), for petitioner-appellant.

Benjamin M. Parker, Washington, D.C. (Johnnie M. Walters, Asst. Atty. Gen., Lee A. Jackson and Crombie J. D. Garrett, Attys., Department of Justice, on the brief), for respondent-appellee.

Before LUMBARD, Chief Judge, FEINBERG, Circuit Judge, and TIMBERS, District Judge.1

PER CURIAM:

We affirm in open court the decision of the Tax Court reported at 50 T.C. No. 19 (1968), which held that Jose V. Ferrer was not a bona fide resident of a foreign country or countries during the calendar year 1962, as provided by Section 911(a)(1), Internal Revenue Code of 1954, so as to avoid liability for income taxes, and determined a deficiency of $122,840.18 after allowing certain deductions for unreimbursed business expenses and disallowing other such claimed expenses.

1

Sitting by designation

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409 F.2d 1359

69-1 USTC P 9425

Jose V. FERRER, Petitioner-Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

No. 527, Docket 32888.

United States Court of Appeals Second Circuit.

Argued May 20, 1969.
Decided May 20, 1969.

Timothy P. Walsh, New York City (Hardin, Hess, Eder & Rashap, New York City, on the brief), for petitioner-appellant.

Benjamin M. Parker, Washington, D.C. (Johnnie M. Walters, Asst. Atty. Gen., Lee A. Jackson and Crombie J. D. Garrett, Attys., Department of Justice, on the brief), for respondent-appellee.

Before LUMBARD, Chief Judge, FEINBERG, Circuit Judge, and TIMBERS, District Judge.1

PER CURIAM:

We affirm in open court the decision of the Tax Court reported at 50 T.C. No. 19 (1968), which held that Jose V. Ferrer was not a bona fide resident of a foreign country or countries during the calendar year 1962, as provided by Section 911(a)(1), Internal Revenue Code of 1954, so as to avoid liability for income taxes, and determined a deficiency of $122,840.18 after allowing certain deductions for unreimbursed business expenses and disallowing other such claimed expenses.

1

Sitting by designation

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